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Francisca Moralez v. Whole Foods Market

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 ...


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