JOINT STIPULATION AND ORDER TO CONTINUE HEARING ON CHASE’S MOTION TO DISMISS 

Case No. 3:17-cv-00392-WHO 

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ANDREW SOUKUP (admitted pro hac vice) 

COVINGTON & BURLING LLP 

One CityCenter 

850 Tenth Street, NW 

Washington, DC 20001 

Telephone: + 1 (202) 662-6000 

Facsimile: + 1 (202) 778-5066 

Email: asoukup@cov.com 

MEGAN L. RODGERS (SBN 310344) 

COVINGTON & BURLING LLP 

333 Twin Dolphin Drive, Suite 700 

Redwood Shores, CA 94065 

Telephone: + 1 (650) 632-4734 

Facsimile: + 1 (650) 632-4834 

Email: mrodgers@cov.com 

LINDSEY BARNHART (SBN 294995) 

COVINGTON & BURLING LLP 

One Front Street, Suite 3500 

San Francisco, CA 94111 

Telephone: +1 415-591-6000 

Facsimile: +1 415-591-6091 

Email: lbarnhart@cov.com 

Attorneys for Defendants Chase Bank USA, N.A. 

and JPMorgan Chase Bank, N.A., 

erroneously sued as JPMorgan Chase Bank 

[Additional counsel on signature page] 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION 

KRISTEN MUEHLENBERG, 

 Plaintiff, 

 v. 

EXPERIAN INFORMATION SOLUTIONS, INC.; 

JPMORGAN CHASE BANK, 

 Defendants. 

 Civil Case No.: 3:17-cv-00392-WHO 

JOINT STIPULATION AND 

ORDER TO CONTINUE 

HEARING ON CHASE’S MOTION TO 

DISMISS 

Original Hearing Date: November 22, 2017 

New Hearing Date: December 6, 2017 
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JOINT STIPULATION AND ORDER TO CONTINUE HEARING ON CHASE’S MOTION TO DISMISS 

Case No. 3:17-cv-00392-WHO 

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Plaintiff Kristen Muehlenberg (“Plaintiff”) and defendants Chase Bank USA, N.A. and 

JPMorgan Chase Bank, N.A., erroneously sued as JPMorgan Chase Bank (collectively, “Chase”) 

respectfully submit the following stipulation to continue the hearing date on Chase’s motion to dismiss 

pursuant to Civil L.R. 7-7 and 6-1. 

1. On October 2, 2017, Chase filed a motion to dismiss Plaintiff’s second amended 

complaint and noticed a hearing date of November 15, 2017. Dkt. No. 41. Plaintiff filed an opposition 

brief on October 16, 2017, Dkt. No. 42, and Chase filed a reply brief on October 23, 2017, Dkt. No. 45. 

2. On November 8, 2017, the Court ordered the parties to submit supplemental briefing on 

the issue of whether the Court may consider Plaintiff’s credit reports when resolving the motion to 

dismiss. Dkt. No. 51. In that same order, the Court continued the hearing on the motion to dismiss to 

November 22, 2017. Id.

3. Chase’s lead counsel has a conflict and is unable to attend the hearing on November 22, 

2017. Declaration of Andrew Soukup in Support of Joint Stipulation and [Proposed] Order to Continue 

Hearing on Chase’s Motion to Dismiss ¶ 4. 

4. Pursuant to Civil L.R. 7-7 and 6-1, all parties agree that the hearing shall be continued 

until December 6, 2017 at 2:00 p.m., subject to the Court’s availability. 

5. The parties have not previously stipulated to continue the hearing date. 

6. This stipulation will not alter the date of any other event or deadline already fixed by 

Court order. 

IT IS SO STIPULATED. 

November 9, 2017 COVINGTON & BURLING LLP 

By: /s/ Megan L. Rodgers 

Megan L. Rodgers 

Andrew Soukup 

Lindsey Barnhart 

Attorneys for Defendants Chase Bank 

USA, N.A. and JPMorgan Chase Bank, 

N.A., erroneously sued as JPMorgan 

Chase Bank 
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JOINT STIPULATION AND ORDER TO CONTINUE HEARING ON CHASE’S MOTION TO DISMISS 

Case No. 3:17-cv-00392-WHO

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November 9, 2017 SAGARIA LAW P.C. 

By: /s/ Elliot W. Gale 

Elliot W. Gale 

Attorneys for Plaintiff Kristen 

Muehlenberg 

ATTESTATION 

 I, Megan L. Rodgers, hereby attest, pursuant to N.D. Cal. Civil L.R. 5-1, that the concurrence to 

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

DATED: November 9, 2017 By: /s/ Megan L. Rodgers 

Megan L. Rodgers 

[PROPOSED] ORDER 

 Pursuant to stipulation, and good cause having been shown, IT IS HEREBY ORDERED that the 

hearing on Chase’s motion to dismiss Plaintiff’s second amended complaint is continued to December 6, 

2017 at 2:00 p.m. 

Dated: ________________ __________________________________ 

 Hon. William H. Orrick III 

 United States District Judge