Free Motion for Extension of Time to File Answer - District Court of California - California

Case 3:07-cv-02174-H-BLM

Document 14

Filed 12/07/2007

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Jeffrey A. LeVee (State Bar No. 125863)
JONES DAY
555 South Flower Street
Fiftieth Floor
Los Angeles, CA 90071-2300
Telephone: (213) 489-3939
Facsimile: (213) 243-2539
[email protected]
Attorneys for Defendant
DOLLAR THRIFTY AUTOMOTIVE GROUP, INC.
Dennis Stewart (State Bar No. 99152)
HULETT HARPER STEWART LLP
550 West "C" Street, Suite 1600
San Diego, CA 92101
Telephone: (619) 338-1133
Facsimile: (619)338-1139
[email protected]
Attorneys for Plaintiffs


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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

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MICHAEL SHAMES; GARY GRAMKOW, on behalf of themselves and on behalf of all persons similarly situated" Plaintiffs,
v.

Case No. 07 CV 2174 H BLM
[Class Action]

THE HERTZ CORPORATION, et aI., Defendants.

JOINT MOTION REGARDING DEFENDANTS' RESPONSE TO THE COMPLAINT

Plaintiffs and defendants hereby jointly move the Court for an order extending the date by which defendants must file their responses to the complaint. Good cause exists for the extension because this is the first request for an extension of time to respond to a twenty-one page complaint alleging antitrust violations. Further, if the Court allows the extension, defendants will be able to attempt to coordinate their responses to the complaint. In further support of this joint motion, the parties state:
JOINT MOTION RE DEFENDANTS' RESPONSE TO THE COMPLAINT
Case Number 07cv2174

Case 3:07-cv-02174-H-BLM

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Filed 12/07/2007

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1.

Plaintiffs initiated this action on November 14, 2007. All defendants either have been served or, by agreeing to this stipulation, hereby

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agree to waive service and any potential challenges to the manner of service of process.

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Defendants have requested, and plaintiffs have agreed, that defendants' responses

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to the complaint shall be filed no later than January 25, 2008.

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The parties have further agreed that, in the event any of the defendants files a

motion to dismiss the complaint, plaintiffs shall have no less than twenty-eight (28) days to file their opposition to such motions (i.e. no earlier than February 22, 2008), and defendants shall have no less than fourteen (14) days thereafter to file their replies, if any, in support of such motions.

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This joint motion does not affect the timing of plaintiffs' motion for preliminary

injunction against the CTTC. For purposes of this joint motion only, counsel for Dollar Thrifty Automotive Group, Inc. is authorized to sign on behalf of all defendants.

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Dated: December

1, 2007
LeVee Counsel for Defendant DOLLAR THRIFTY AUTOMOTIVE GROUP, INC. AND SPECIALLY APPEARING ON BEHALF OF ALL DEFENDANTS FOR THE PURPOSES OF THIS MOTION ONLY

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JOINT MOTION RE DEFENDANTS' RESPONSE
LAI-2918852v I

TO THE COMPLAINT

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Case Number 07cv2174

Case 3:07-cv-02174-H-BLM

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Filed 12/07/2007

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Dated: December 2
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1', 2007

CENTER FOR PUBLIC INTEREST LAW

UNIVERSITY OF SAN DIEGO SCHOOL OF
LAW SULLIV AN HILL LEWIN REZ & ENGEL Counsel for Plaintiffs

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LAI-2918852vI

JOINT MOTION RE DEFENDANTS' RESPONSE TO THE COMPLAINT

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Case Number 07cv2174