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

Case 3:07-cv-02129-BTM-AJB

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Filed 12/12/2007

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MAYER BROWN LLP JOHN NADOLENCO (SBN 181128) [email protected] BRONWYN F. POLLOCK (SBN 210912) [email protected] 350 South Grand Avenue, 25th Floor Los Angeles, CA 90071-1503 Telephone: (213) 229-9500 Facsimile: (213) 625-0248 Attorneys for Defendant COURTYARD HOLDINGS, LP UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

OUTERBRIDGE ACCESS ASSOCIATION, SUING ON BEHALF OF DIANE CROSS; and DIANE CROSS, An Individual, Plaintiffs, v. MARIE CALLENDER'S PIE SHOPS, INC. d.b.a. MARIE CALLENDER'S #254; PACIFIC BAGELS, LLC d.b.a. BRUEGGARS BAGELS; COURTYARD HOLDINGS, LP; PSS PARTNERS, LLC; AND DOES 1 THROUGH 10, Inclusive, Defendants.

CASE NO. 07 CV 2129 BTM (AJB) JOINT MOTION FOR EXTENSION OF TIME FOR DEFENDANT COURTYARD HOLDINGS, LP TO FILE A RESPONSIVE PLEADING TO PLAINTIFFS' COMPLAINT [CivLR 7.2, 12.1] Honorable Barry T. Moskowitz

JOINT MOTION FOR EXTENSION OF TIME FOR DEFENDANT COURTYARD HOLDINGS, LP TO FILE A RESPONSIVE PLEADING TO PLAINTIFFS' COMPLAINT; CASE NO. 07 CV 2129 BTM (AJB)

Case 3:07-cv-02129-BTM-AJB

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Plaintiffs, Outerbridge Access Association, Suing on Behalf of Diane Cross, and Diane Cross (jointly, "Plaintiffs"), and Defendant Courtyard Holdings, LP ("Defendant"), through their counsel of record, jointly move the Court and stipulate as follows: Whereas, Plaintiffs' Complaint initiating this action was filed on November 7, 2007; Whereas, Defendant's registered agent for service of process, Corporation Service Company, received the Complaint on November 7, 2007 and thereafter provided the Complaint to Defendant's separate parent entity, Clarion Partners, LLC, in Washington, DC; Whereas, the portfolio administrator in Washington, DC who received the Complaint on behalf of Clarion Partners, LLC experienced health problems and was unable to act in response to the Complaint until a few days before the response was due; Whereas, on November 28, 2007, Plaintiffs and Defendant filed a Joint Motion for Extension of Time for Defendant Courtyard Holdings, LP to File a Responsive Pleading to Plaintiffs' Complaint (the "Joint Motion"); Whereas, on November 30, 2007, the Court granted the parties' Joint Motion and extended the time for Defendant Courtyard Holdings, LP to respond to the Complaint until December 12, 2007; Whereas, Plaintiffs have provided Defendant with a settlement offer, and Defendant is currently reviewing that offer and needs additional time to file its response to the Complaint; Whereas, pursuant to Rules 7.2 and 12.1 of the Local Civil Rules of Practice for the United States District Court for the Southern District of California, Plaintiffs and Defendant have stipulated that Defendant Courtyard Holdings, LP shall have a further extension, to and including January 11, 2008, to file its responsive pleading to the Complaint. IT IS HEREBY STIPULATED that Defendant Courtyard Holdings, LP shall have to and including January 11, 2008 to file its responsive pleading to the Complaint. Accordingly, Plaintiffs and Defendant hereby move the Court to enter the Order Granting Joint Motion for Extension of Time for Defendant Courtyard Holdings, LP to File a Responsive Pleading to Plaintiffs' Complaint concurrently lodged with the Court. -1JOINT MOTION FOR EXTENSION OF TIME FOR DEFENDANT COURTYARD HOLDINGS, LP TO FILE A RESPONSIVE PLEADING TO PLAINTIFFS' COMPLAINT; CASE NO. 07 CV 2129 BTM (AJB)
28738576

Case 3:07-cv-02129-BTM-AJB

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IT IS SO STIPULATED. December 12, 2007 PINNOCK & WAKEFIELD, A.P.C. THEODORE A. PINNOCK DAVID C. WAKEFIELD MICHELLE L. WAKEFIELD

By: s/ Michelle L. Wakefield Michelle L. Wakefield Attorneys for Plaintiffs OUTERBRIDGE ACCESS ASSOCIATION, SUING ON BEHALF OF DIANE CROSS, AND DIANE CROSS E-mail: [email protected] December 12, 2007 MAYER BROWN LLP JOHN NADOLENCO BRONWYN F. POLLOCK

By: s/ Bronwyn F. Pollock Bronwyn F. Pollock Attorneys for Defendant COURTYARD HOLDINGS, LP E-mail: [email protected]

-2JOINT MOTION FOR EXTENSION OF TIME FOR DEFENDANT COURTYARD HOLDINGS, LP TO FILE A RESPONSIVE PLEADING TO PLAINTIFFS' COMPLAINT; CASE NO. 07 CV 2129 BTM (AJB)
28738576

Case 3:07-cv-02129-BTM-AJB

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Filed 12/12/2007

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Case 3:07-cv-02129-BTM-AJB

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Case 3:07-cv-02129-BTM-AJB

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