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Heather Newton, Individually and Behalf of Others Similarly Situated v. American Debt Services

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION


November 4, 2011

HEATHER NEWTON, INDIVIDUALLY AND BEHALF OF OTHERS SIMILARLY SITUATED, PLAINTIFF,
v.
AMERICAN DEBT SERVICES, INC., A CALIFORNIA CORPORATION; QUALITY SUPPORT SERVICES, LLC, A CALIFORNIA LIMITED LIABILITY COMPANY; GLOBAL CLIENT SOLUTIONS, LLC; ROCKY MOUNTAIN BANK TRUST; AND DOES 1-100, DEFENDANTS.

The opinion of the court was delivered by: Edward M. Chen U.S. District Judge

RICHARD W. EPSTEIN (FLA. BAR NO: 229091) 1(Pro Hac Vice Admission Pending) Richard.Epstein@gmlaw.com 2REBECCA F. BRATTER (FLA. BAR NO: 0685100) (Pro Hac Vice Admission Pending) 3Rebecca.Bratter@gmlaw.com GREENSPOON MARDER, P.A. 4Trade Centre South, Suite 700 100 W. Cypress Creek Road, Suite 700 5Ft. Lauderdale, FL 33309 954-491-1120 6954-343-6958(facsimile) 7ROBERT S. BOULTER (SBN 153549) rsb@lb-attorneys.com 8PETER C. LAGARIAS (SBN 77091) rsb@lb-attorneys.com 9LAGARIAS & BOULTER, LLP 1629 Fifth Avenue 10San Rafael, California 94901-1828 Telephone: (415) 460-0100 11Facsimile: (415) 460-1099 Attorneys for Defendants 13Global Client Solutions, LLC and Rocky Mountain Bank and Trust

CLASS ACTION

PLAINTIFF HEATHER NEWTON DEFENDANTS GLOBAL CLIENT SOLUTIONS, LLC & ROCKY MOUNTAIN BANK & TRUST'S STIPULATION TO EXTEND DEADLINE TO RESPOND TO COMPLAINT; ORDER

Pursuant to both L. R. 6-1(a) & 6-2, Plaintiff Heather Newton ("Plaintiff") and Defendants Rocky Mountain Bank & Trust ("RMBT") and Global Client Solutions, LLC ("Global") (collectively, "Defendants") (all, "Parties") file this Stipulation to Extend Defendants' Deadline to Respond to the Class Action 6Complaint from November 4, 2011 to November 7, 2011, and state as follows:

WHEREAS, according to the parties' Stipulation dated October 10, 2011 ("Initial Stipulation") [D.E. 19], Defendants' deadline to respond to the Class Action Complaint is November 4, 2011.

WHEREAS, after conferring with Counsel for Plaintiff, due to competing time demands, the Parties hereby stipulate that Defendants may have through November 7, 2011 to file their response(s) to the Class Action Complaint.

WHEREAS, furthermore, this Stipulation does not affect the other agreed- upon deadlines from the Initial Stipulation as Plaintiff shall still have through 18December 2, 2011 to file her opposition to Defendants' forthcoming motion and Defendants shall have through December 23, 2011 to file their reply.

WHEREAS, this Stipulation will not have an effect on the schedule for this case.

WHEREFORE, Plaintiff Heather Newton and Defendants Rocky Mountain Bank & Trust and Global Client Solutions, LLC stipulate to extend the deadline for 26Defendants to respond to the Class Action Complaint from November 4, 2011 to November 7, 2011.

IT IS SO ORDERED:

IT IS SO ORDERED

Edward M. Chen Judge

CERTIFICATE OF SERVICE

I hereby certify that on this 4th day of November, 2011, I electronically filed the 4foregoing document with the Clerk of Court using CM/ECF. I also certify that the 5foregoing document is being served this day on all counsel of record or pro se parties in the manner specified, either via transmission of Notices of Electronic 8Filing generated by CM/ECF or in some other authorized manner for those counsel 9or parties who are not authorized to receive electronically Notices of Electronic Filing.

Richard W. Epstein

7287326 v1

20111104

© 1992-2011 VersusLaw Inc.



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