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JOINT STIPULATION AND [PROPOSED] ORDER FOR 

EXTENSION OF TIME TO RESPOND TO COMPLAINT

Case No. 3:17-cv-00423-EMC

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 

COLBI TROESTER-MILLER,

Plaintiff,

v.

EXPERIAN INFORMATION SOLUTIONS, 

INC.; ET AL.,

Defendants.

Case No. 3:17-cv-00423-EMC

Assigned to: Judge Edward M. Chen

JOINT STIPULATION AND 

[PROPOSED] ORDER FOR

EXTENSION OF TIME TO RESPOND 

TO COMPLAINT

Case 3:17-cv-00423-EMC Document 16 Filed 03/06/17 Page 1 of 4
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- 1 -

JOINT STIPULATION AND [PROPOSED] ORDER FOR 

EXTENSION OF TIME TO RESPOND TO COMPLAINT

Case No. 3:17-cv-00423-EMC

On January 26, 2017, Plaintiff Colbi Troester-Miller (“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

Colbi Troester-Miller

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.

Case 3:17-cv-00423-EMC Document 16 Filed 03/06/17 Page 2 of 4
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JOINT STIPULATION AND [PROPOSED] ORDER FOR 

EXTENSION OF TIME TO RESPOND TO COMPLAINT

Case No. 3:17-cv-00423-EMC

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.

Case 3:17-cv-00423-EMC Document 16 Filed 03/06/17 Page 3 of 4
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[PROPOSED] ORDER FOR EXTENSION OF TIME TO 

RESPOND TO COMPLAINT

Case No. 3:17-cv-00423-EMC

[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 Edward M. Chen

3/6/17

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge Edward M. Chen

Case 3:17-cv-00423-EMC Document 16 Filed 03/06/17 Page 4 of 4