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28 1 

JOINT STIPULATION AND [PROPOSED] ORDER CONCERNING TIME TO FILE 

RESPONSE TO AMENDED COMPLAINT 

CASE NO. 3:16-CV-07212-EMC 

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DYKEMA GOSSETT LLP

Tamara A. Bush (SBN 197153) 

tbush@dykema.com

John M. Thomas (SBN. 266842) 

jthomas@dykema.com 

Janet L. Conigliaro (P72629) Pro Hac Vice 

jconigliaro@dykema.com 

333 South Grand Avenue 

Suite 2100 

Los Angeles, CA 90071 

Telephone: (213) 457-1800 

Facsimile: (213) 457-1850 

Attorneys for Defendant 

TOYOTA MOTOR SALES, U.S.A., INC. 

GLANCY PRONGAY & MURRAY LLP 

Lionel Z. Glancy (#134180) 

Mark S. Greenstone (#199606) 

1925 Century Park East, Suite 2100 

Los Angeles, California 90067 

Telephone: (310) 201-9150 

Facsimile: (310) 201-9160 

E-mail: mgreenstone@glancylaw.com 

Attorneys for Plaintiffs 

MICHAEL ROBEY, MOE ASGHARNIA and 

JAMES COMB Individually and On Behalf 

of a Class of Similarly Situated Individuals

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA, 

SAN FRANCISCO DIVISION 

MICHAEL ROBEY, MOE ASGHARNIA and

JAMES COMB Individually and On Behalf of a 

Class of Similarly Situated Individuals, 

Plaintiffs, 

vs. 

TOYOTA MOTOR SALES, U.S.A., INC. and 

TOYOTA MOTOR CORPORATION, 

Defendants. 

_______________________________________

Case No. 3:16-cv-07212-EMC

[Assigned to Hon. Edward M. Chen] 

CLASS ACTION 

JOINT STIPULATION AND [PROPOSED] 

ORDER CONCERNING TIME TO FILE 

RESPONSE TO AMENDED COMPLAINT 

Complaint Filed: December 16, 2016 

Complaint Served: January 6, 2017 

1

st Amended Complaint Filed: April 7, 2017 
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28 2 

JOINT STIPULATION AND [PROPOSED] ORDER CONCERNING TIME TO FILE 

RESPONSE TO AMENDED COMPLAINT 

CASE NO. 3:16-CV-07212-EMC 

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Plaintiff MICHAEL ROBEY, MOE ASGHARNIA and JAMES COMB Individually and On 

Behalf of a Class of Similarly Situated Individuals (“Plaintiffs”), and Defendant TOYOTA 

MOTOR SALES, U.S.A., INC. (“Defendant”) (collectively the “Parties”), by and through their 

respective counsel, hereby stipulate as follows: 

WHEREAS, Plaintiffs filed this putative class action complaint against Defendant in the 

Northern District of California, San Francisco Division, on December 16, 2016 (the “Complaint”); 

WHEREAS, Plaintiffs served the Complaint on Defendant on January 5, 2017; 

WHEREAS, Defendant filed a Motion to Dismiss the Complaint on February 24, 2017; 

WHEREAS, Plaintiffs filed an Amended Complaint on April 7, 2017, containing 

significant amendments; 

WHEREAS, Defendant’s response to Plaintiffs’ Amended Complaint is currently due on 

May 12, 2017; 

WHEREAS, the Parties are engaged in discussions to determine whether it is feasible to 

resolve this matter without the need for further litigation; 

WHEREAS, the Parties agree that a brief two-week continuance of the deadline for 

Defendant to respond to Plaintiffs’ Amended Complaint will facilitate the Parties’ settlement 

discussions, and result in a more efficient expenditure of judicial resources; 

WHEREAS, the Parties request that Defendant’s deadline to respond to Plaintiffs’ 

Amended Complaint, currently set for May 12, 2017, be continued to May 26, 2017; 

WHEREAS, the Parties have previously requested one extension of time for Defendant to 

file a response to Plaintiffs’ Amended Complaint; 

WHEREAS, counsel for Defendant, as the filer of this document, attests that concurrence in 

the filing of the document has been obtained from each of the other signatories; 

IT IS THEREFORE STIPULATED BETWEEN THE PARTIES THAT, subject to the 

Court’s approval: 

1. Defendant’s response to Plaintiffs’ Amended Complaint shall be continued from 

May 12, 2017, until May 26, 2017. 
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28 3 

JOINT STIPULATION AND [PROPOSED] ORDER CONCERNING TIME TO FILE 

RESPONSE TO AMENDED COMPLAINT 

CASE NO. 3:16-CV-07212-EMC 

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Dated: May 9, 2017 DYKEMA GOSSETT LLP

By: /s/ Tamara A. Bush . 

John M. Thomas 

Tamara A. Bush 

Attorneys for Defendant 

TOYOTA MOTOR SALES, U.S.A., INC. 

Dated: May 9, 2017 GLANCY PRONGAY & MURRAY LLP

By: /s/ Mark S. Greenstone . 

Lionel Z. Glancy 

Mark S. Greenstone 

Attorneys for Plaintiffs 

MICHAEL ROBEY, MOE ASGHARNIA 

and JAMES COMB Individually and On 

Behalf of a Class of Similarly Situated 

Individuals

General Order 45, Section X Certification 

The filing attorney hereby certifies that concurrence in the filing of the document has been 

obtained from each signatory, in accordance with N.D. Cal. Gen. Order 45, Section X(B). 
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28 4 

JOINT STIPULATION AND [PROPOSED] ORDER CONCERNING TIME TO FILE 

RESPONSE TO AMENDED COMPLAINT 

CASE NO. 3:16-CV-07212-EMC 

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[PROPOSED] ORDER 

Having reviewed the Parties’ Joint Stipulation and [Proposed] Order Concerning Time to 

File Response to Amended Complaint, and for good cause appearing, IT IS HEREBY ORDERED 

THAT: 

1. Defendant’s response to Plaintiffs’ Amended Complaint shall be continued from 

May 12, 2017, until May 26, 2017. 

IT IS SO ORDERED. 

DATED:________________ By: ________________________________ 

HON. EDWARD M. CHEN 

UNITED STATES DISTRICT JUDGE 

May 10, 2017

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge Edward M. Chen