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

Case 3:07-cv-02126-BEN-RBB

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Filed 11/26/2007

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1 NANCY SHER COHEN (Bar No. 81706) [email protected] 2 RONALD A. VALENZUELA (Bar No. 210025) [email protected] 3 HELLER EHRMAN LLP 333 South Hope Street, 39th Floor 4 Los Angeles, CA 90071-3043 5 Telephone: +1.213.689.0200 Facsimile: +1.213.614.1868 6 Attorneys for Defendant 7 SONY ELECTRONICS INC. Additional Counsel for Parties Joining This Motion Listed on Signature Page 8 UNITED STATES DISTRICT COURT 9 10 SOUTHERN DISTRICT OF CALIFORNIA CV No. 07cv2126-JM(NLS) JOINT MOTION FOR ORDER EXTENDING SONY ELECTRONICS INC.'S TIME TO RESPOND TO COMPLAINT

11 JASON DEMAS and JOHN RENNINGER, on 12 their own behalves and on behalf of all others similarly situated, 13 Plaintiffs, 14 15 v.

16 SONY ELECTRONICS INC., 17 18 19 20 21 22 23 24 25 26 27 28 Defendant.

The Honorable Jeffrey T. Miller Courtroom: 6

Pursuant to Local Rule 7.2, Plaintiffs Jason Demas and John Renninger and Defendant Sony Electronics Inc. ("SEL"), by and through their respective counsel, hereby submit this Joint Motion for an Order extending SEL's time to respond to the Complaint. On November 6, 2007, Plaintiffs filed their Complaint in the above-entitled action and subsequently served the Complaint on SEL on November 7, 2007. Pursuant to Federal Rule of Civil Procedure 12(a)(1)(A), SEL has until November 27, 2007 to answer or otherwise respond to the Complaint. Plaintiffs' Complaint includes a claim for injunctive relief under California's Consumer Legal Remedies Act ("CLRA"). Plaintiffs' counsel has advised counsel for SEL

JOINT MOT. FOR ORDER EXTENDING SONY ELECTRONICS INC.'S TIME TO RESPOND TO COMPL. CV No. 07cv2126-JM(NLS)

Case 3:07-cv-02126-BEN-RBB

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1 that Plaintiffs intend to amend their complaint to include a claim for damages under the 2 CLRA. 3 The parties agree that good cause exists for extending the deadline for SEL to answer

4 or otherwise respond to the Complaint. An extension will save the parties time and 5 resources by obviating the need for SEL to respond to the Complaint -- prior to Plaintiffs 6 filing an amended complaint -- only to have that response, and any concomitant briefing, 7 rendered moot by Plaintiffs' subsequent filing of an amended complaint. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 DATED: November 21, 2007 24 25 26 27 28 2
JOINT MOT. FOR ORDER EXTENDING SONY ELECTRONICS INC.'S TIME TO RESPOND TO COMPL. CV No. 07cv2126-JM(NLS)

Therefore, the parties agree as follows: · SEL shall have until December 20, 2007 to respond to the Complaint if Plaintiffs have not filed an amended complaint by December 10, 2007; · Plaintiffs may file an amended complaint up to and including December 10, 2007, but in no event before November 30, 2007; and · SEL shall have (a) 20 days from the date Plaintiffs serve their amended complaint, or (b) up to and including December 30, 2007, whichever occurs first, to answer or otherwise respond to Plaintiffs' amended complaint. Accordingly, the parties respectfully request that this Joint Motion be granted. Respectfully submitted, DATED: November 21, 2007 HELLER EHRMAN LLP

By

s/Ronald Valenzuela RONALD VALENZUELA Attorneys for Defendant SONY ELECTRONICS INC.

KamberEdelson LLC

By

s/Alan Himmelfarb ALAN HIMMELFARB Attorneys for Plaintiffs

Case 3:07-cv-02126-BEN-RBB

Document 8

Filed 11/26/2007

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Case 3:07-cv-02126-BEN-RBB

Document 8

Filed 11/26/2007

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