1

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF MICHIGAN

ROSE COULTER-OWENS, 

individually, and on behalf of all others 

similarly situated,

Plaintiff,

v.

RODALE, INC., a Pennsylvania 

corporation, 

Defendant.

Case No.: 2:14-cv-12688

Hon. Victoria A. Roberts

Mag. Judge R. Steven Whalen

JOINT STIPULATION TO EXTEND BRIEFING SCHEDULE

This Joint Stipulation is entered into by and amongst Plaintiff Rose Coulter 

Owens (“Plaintiff”), and Defendant Rodale, Inc. (“Defendant”), by and through 

their respective counsel.

WHEREAS, on July 9, 2014, Plaintiff filed the instant putative class action 

lawsuit against Defendant (Dkt. 1);

WHEREAS, on August 19, 2014, the Parties filed a Joint Stipulation 

extending the time for Defendant to Answer, Move, or Otherwise Plead to the 

Complaint (Dkt. 10);

WHEREAS, on August 21, 2014, this Court granted the Parties’ Joint 

Stipulation extending the time for Defendant to Answer, Move, or Otherwise Plead 

to the Complaint (Dkt. 11);

2:14-cv-12688-RHC-RSW Doc # 16 Filed 10/08/14 Pg 1 of 4 Pg ID 142
2

WHEREAS, on September 18, 2014, Defendant timely filed its Motion to 

Dismiss the Complaint (Dkt. 14);

WHEREAS, Plaintiff’s response deadline is October 9, 2014, and 

Defendant’s reply deadline is October 23, 2014;

WHEREAS, a hearing on Defendant’s Motion to Dismiss has not yet been 

scheduled;

WHEREAS, Plaintiff’s counsel conferred with Defendant’s counsel and, in 

light of the intervening Jewish holiday and other scheduling commitments, the 

Parties agree, subject to Court approval, to extend the time for Plaintiff to respond 

to Defendant’s pending Motion by seven (7) days, until October 16, 2014, and to 

extend the time for Defendant to file its reply in support of its pending Motion by 

seven (7) days, until October 30, 2014;

WHEREAS, this Stipulation is sought in good faith and not brought for 

purposes of delay, and will not affect any pending deadlines or hearings; 

NOW THEREFORE, the Parties hereby STIPULATE and AGREE as 

follows, subject to Court approval:

1. Plaintiff’s deadline to file her Response in opposition to Defendant’s 

Motion to Dismiss shall be October 16, 2014; and 

2. Defendant’s deadline to file its Reply in support of its Motion to 

Dismiss shall be October 30, 2014.

2:14-cv-12688-RHC-RSW Doc # 16 Filed 10/08/14 Pg 2 of 4 Pg ID 143
3

IT IS SO STIPULATED.

Respectfully submitted,

Dated: October 8, 2014 Rose Coulter-Owens, individually and on 

behalf of all others similarly situated,

By: /s/ Ari J. Scharg

One of Plaintiff’s Attorneys

Ari J. Scharg

ascharg@edelson.com

John C. Ochoa

jochoa@edelson.com

J. Dominick Larry

nlarry@edelson.com

Mark S. Eisen

meisen@edelson.com

EDELSON PC

350 North LaSalle Street, Suite 1300

Chicago, Illinois 60654

Tel: 312.589.6370 

Fax: 312.589.6378

Henry M. Scharg – P28804

hmsattyatlaw@aol.com

LAW OFFICE OF HENRY M. SCHARG

302 W. Main Street

Northville, Michigan 48167

Tel: 248.596.1111

Fax: 248.596.1578

Counsel for Plaintiff Coulter-Owens and the 

putative class

2:14-cv-12688-RHC-RSW Doc # 16 Filed 10/08/14 Pg 3 of 4 Pg ID 144
4

Dated: October 8, 2014 Rodale, Inc.

By:/s/ Anthony T. Eliseuson 

(with permission)

One of Defendant’s attorneys

Anthony T. Eliseuson 

Natalie J. Spears 

Kristen C. Rodriguez 

DENTONS US LLP

233 South Wacker Drive 

Suite 7800 

Chicago, IL 60606 

(312) 876-8000 

(312) 876-7934 (fax) 

anthony.eliseuson@dentons.com

natalie.spears@dentons.com 

kristen.rodriguez@dentons.com 

Peter B. Kupelian (P31812) 

Carol G. Schley (P51301)

CLARK HILL PLC 

500 Woodward Avenue, Suite 3500 

Detroit, MI 48226 

pkupelian@clarkhill.com 

cschley@clarkhill.com 

Counsel for Defendant Rodale, Inc.

2:14-cv-12688-RHC-RSW Doc # 16 Filed 10/08/14 Pg 4 of 4 Pg ID 145