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Francisca Moralez v. Whole Foods Market

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


May 8, 2012

FRANCISCA MORALEZ,
PLAINTIFF,
v.
WHOLE FOODS MARKET, INC.; BOND CC OAKLAND LLC; AND DOES 1-10, INCLUSIVE DEFENDANTS.

The opinion of the court was delivered by: United States District Charles R. Breyer Judge

[Complaint Filed March 2, 2012]

STIPULATION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE 21 RESPOND TO PLAINTIFF'S 22 COMPLAINT; [PROPOSED] ORDER

STIPULATION

1. WHEREAS this action was filed by Plaintiff Francisca Moralez on

March 2, 2012 and served on Defendant Whole Foods Market California, Inc. (erroneously 5 sued and served as Whole Foods Market, Inc.) ("Defendant") on March 22, 2012; 6 7

2. WHEREAS April 12, 2012 is the date upon which Defendant must 8 file and serve an answer or otherwise respond to Plaintiff's Complaint; 9 10

3. WHEREAS good cause exists for an extension of time because 4 Defendant needs additional time to investigate adequately the claims alleged in this matter, 12 as well as all potential defenses and/or counterclaims to those claims; 13 14

4. WHEREAS Plaintiff does not oppose and has agreed to Defendant's 15 request that it may have through and including May 11, 2012 to answer or otherwise 16 respond to Plaintiff's Complaint; 17 18 5. WHEREAS the parties have not previously requested extensions of 19 time from this Court; 20 21

NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the 22 parties, through their counsel, that this Court should extend the deadline for Defendant to 23 answer or otherwise respond to Plaintiff's Complaint through and including the date of 24

May 11, 2012.

Counsel for Plaintiff has agreed to the electronic filing of this Stipulation and 2 requested that Defendant's counsel submit an electronic signature on his behalf. 3 4

Dated: April 11, 2012 5 LAW OFFICES OF PAUL L. REIN 6 7 By /s/ Paul L. Rein PAUL L. REIN 8 CELIA MCGUINNESS 9 CATHERINE M. CABALO 10 Attorneys for Plaintiff 11 FRANCISCA MORALEZ 12 Dated: April 11, 2012 13 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP 14 15 By /s/ Hayley S. Grunvald 16 RICHARD J. SIMMONS 17 DEREK R. HAVEL HAYLEY S. GRUNVALD 18 19 Attorneys for Defendant WHOLE FOODS MARKET CALIFORNIA, INC. 20 (ERRONEOUSLY SUED AND SERVED AS WHOLE FOODS MARKET, INC.)

ORDER

Having reviewed and considered the above Stipulation of the parties, and 3 good cause appearing, IT IS SO ORDERED that the deadline for the Defendant Whole 4

Foods Market California, Inc. (erroneously sued and served as Whole Foods Market, Inc.) 5 to respond to the complaint is hereby extended until May 11, 2012. 6 7

PURSUANT TO STIPULATION, IT IS SO ORDERED.

MAGISTRATE

IT IS JUDGE LAUREL BEELER

SO ORDERED

PROOF OF SERVICE

STATE OF CALIFORNIA, COUNTY OF SAN DIEGO

I am employed in the County of San Diego; I am over the age of eighteen years and not a party to the within entitled action; my business address is 501 West Broadway, 19th 4

Floor, San Diego, California 92101-3598. 5

On April 12, 2012, I served the following documents:6

STIPULATION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT 7

BY ELECTRONIC MAIL: I caused the above-entitled documents to be served through 8

CM ECF addressed to all parties appearing on the CM ECF electronic service list for the above-entitled case. The file transmission was reported as completed and a copy of the 9

CM ECF Filing Receipt will be maintained with the original documents in our office. 10

Electronic Mail Notice List

The following are those who are currently on the list to receive e-mail notices for this case. 12 Paul L. Rein, Esq. Celia McGuinness, Esq. 13 Catherine M. Cabalo, Esq. LAW OFFICES OF PAUL L. REIN 14 200 Lakeside Drive, Suite A Oakland, CA 94612 15 Telephone: (510) 832-5001 Facsimile: (510) 832-4787 16 Attorneys for Plaintiff 17

I declare that I am employed in the office of a member of the bar of this Court at whose direction the service was made. I declare under penalty of perjury under the laws of 18 the United States of America that the foregoing is true and correct. 19

Executed on April 12, 2012, at San Diego, California. 20 21

/s/ Hayley S. Grunvald

HAYLEY S. GRUNVALD

20120508

© 1992-2012 VersusLaw Inc.



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