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JOINT STIPULATION AND [PROPOSED] ORDER FOR 

EXTENSION OF TIME TO RESPOND TO COMPLAINT 

Case No. 3:17-cv-00424-RS 

Benjamin C. Lee (SBN 282177) 

blee@jonesday.com 

JONES DAY 

555 California Street, 26th Floor 

San Francisco, CA 94104 

Telephone: (415) 626-3939 

Facsimile: (415) 875-5700 

Attorneys for Defendant 

EXPERIAN INFORMATION SOLUTIONS, INC. 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

VICTOR VAZQUEZ, 

Plaintiff, 

v. 

EXPERIAN INFORMATION SOLUTIONS, 

INC.; ET AL., 

Defendants. 

Case No. 3:17-cv-00424-RS

Assigned to: Judge Richard Seeborg 

JOINT STIPULATION AND 

[PROPOSED] ORDER FOR 

EXTENSION OF TIME TO RESPOND 

TO COMPLAINT

 

Case 3:17-cv-00424-RS Document 14 Filed 03/03/17 Page 1 of 4
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JOINT STIPULATION AND [PROPOSED] ORDER FOR 

EXTENSION OF TIME TO RESPOND TO COMPLAINT 

Case No. 3:17-cv-00424-RS 

On January 26, 2017, Plaintiff Victor Vazquez (“Plaintiff”) filed a Complaint in this 

action. Given the large volume of Complaints requiring a response from Defendant Experian 

Information Solutions, Inc. (“Experian”) at the same time, and in accordance with Local Rule 6-

1(a), Plaintiff and Experian agree to an extension for Experian to answer or otherwise respond to 

the Complaint. Experian’s response to the Complaint is due April 3, 2017. To the extent that 

Experian files a motion to dismiss in this case, Experian agrees that Plaintiff shall have 30 days to 

respond. Experian will thereupon have 21 days for any reply. 

Accordingly, IT IS HEREBY STIPULATED by and between Plaintiff and Experian, that 

the deadline for Experian to answer or otherwise respond to the Complaint is extended until April 

3, 2017. Plaintiff’s deadline to respond to any motion to dismiss is extended to 30 days from 

filing, and Experian’s deadline to reply in support of a motion to dismiss is extended to 21 days 

from filing the opposition. 

Dated: March 2, 2017 /s/ Elliot W. Gale 

Elliot W. Gale (SBN 263326) 

SAGARIA LAW, P.C. 

2033 Gateway Place, 5th Floor 

San Jose, CA 95110 

Tele.: (408) 279-2288 

Fax: (408) 279-2299 

Email: egale@sagarialaw.com 

Attorneys for Plaintiff 

Victor Vazquez 

Dated: March 2, 2017 /s/ Benjamin C. Lee 

Benjamin C. Lee (SBN 282177) 

JONES DAY 

555 California Street, 26th Floor 

San Francisco, CA 94104 

Telephone: (415) 626-3939 

Facsimile: (415) 875-5700 

Email: blee@jonesday.com 

Attorneys for Defendant 

Experian Information Solutions, Inc. 

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JOINT STIPULATION AND [PROPOSED] ORDER FOR 

EXTENSION OF TIME TO RESPOND TO COMPLAINT 

Case No. 3:17-cv-00424-RS 

ECF CERTIFICATION

I, Benjamin C. Lee, hereby attest pursuant to Local Rule 5-1(i)(3) that the concurrence to 

the filing of this document has been obtained from each signatory hereto. 

Executed on March 2, 2017, at San Francisco, California. 

/s/ Benjamin C. Lee 

Benjamin C. Lee (SBN 282177) 

JONES DAY 

Attorneys for Defendant 

Experian Information Solutions, Inc.

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[PROPOSED] ORDER FOR EXTENSION OF TIME TO 

RESPOND TO COMPLAINT 

Case No. 3:17-cv-00424-RS 

[PROPOSED] ORDER 

The Court, having considered the parties’ Joint Stipulation for Extension of Time to 

Respond to the Complaint, hereby extends Experian Information Solutions, Inc.’s (“Experian”) 

deadline to answer or otherwise respond to the Complaint to April 3, 2017. Plaintiff’s deadline to 

respond to any motion to dismiss is extended to 30 days from filing, and Experian’s deadline to 

reply in support of a motion to dismiss is extended to 21 days from filing the opposition. 

PURSUANT TO THE STIPULATION, IT IS SO ORDERED. 

DATED: __________________________ 

The Honorable Judge Richard Seeborg 

3/3/17

Case 3:17-cv-00424-RS Document 14 Filed 03/03/17 Page 4 of 4