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Jackie L. High, Individually and On Behalf Others Similarly Situated v. the Choice Manufacturing Company

January 10, 2012

JACKIE L. HIGH, INDIVIDUALLY AND ON BEHALF OTHERS SIMILARLY SITUATED,
PLAINTIFF,
v.
THE CHOICE MANUFACTURING COMPANY, INC., MEPCO FINANCE
CORPORATION, AND DOES 3 THROUGH 20, INCLUSIVE,
DEFENDANTS.



The opinion of the court was delivered by: The Honorable Edward M. Chen United States

CLASS ACTION STIPULATION AND [PROPOSED] ORDER

REGARDING AMENDING COMPLAINT of All AND EXTENSION OF TIME TO ANSWER OR OT HERWISE RESPOND TO FIRST AMENDED COMPLAINT

violation of California Business & Professions Code Sections 17200 and 17500, et seq.; Breach 3 of Contract and the Covenant of Good Faith & Fair Dealing; and breach of Express Warranty 4 against The Choice Manufacturing Company, Inc. ("Choice Manufacturing") and MEPCO Finance Corporation ("MEPCO"), captioned High v. The Choice Manufacturing Company, Inc., 6 et al.,Case No. CV-11-05478-EMC; 7 pursuant to Federal Rule of Civil Procedure 15(a); 9

WHEREAS, on November 10, 2011, plaintiff Jackie L. High filed a complaint for WHEREAS on December 15, 2011, plaintiff filed an Amended Complaint ("AC")

WHEREAS defendant MEPCO has until January 11, 2012 and defendant Choice Manufacturing has until January 17, 2012 to answer or otherwise respond to the AC; 11 the Consumer Legal Remedies Act ("CLRA") against defendant Choice Manufacturing; 13 requirement in Cal. Civ. Code §1782(a)(2); 15 violation of the CLRA against Choice Manufacturing and allowing defendants additional time in 17 which to answer or respond to the such amended pleading; 18 parties, that 20

WHEREAS plaintiff wishes to further amend the AC to include a claim for violation of

WHEREAS plaintiff could not have included this claim in the AC because of the notice

WHEREAS defendants are amenable to plaintiff amending her AC to include a claim for

IT IS ACCORDINGLY STIPULATED, by and between undersigned counsel for the (1) Plaintiff will file and serve her First Amended Complaint ("FAC") by January 11, 2012;

(2) Defendants Choice Manufacturing and MEPCO will have until February 17, 2012 to answer or otherwise respond to the FAC.

DATED: January 10, 2012 THE MEHDI FIRM 25 26 27 28 /s/ AZRA Z. MEHDI One Market Spear Tower, Suite 3600 San Francisco, CA 94105 Telephone: 415/293-8039 Fax: 415/293-8001 Azram@themehdifirm.com Counsel for Plaintiff Jackie L. High

DATED: January 10, 2012 DOWNEY BRAND 7

/s/ JAMIE DREHER 621 Capital Mall, 18 Floor Sacramento, CA 95814 Telephone: 916/444-1000 Fax: 916/444-2100 jdreher@downeybrand.com Counsel ...


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