MMRGlobal, Inc. (fka MMRF)

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Case 2:13-cv-09214-ODW-SH Document 21 Filed 02/04/14 Page 1 of 5 Page ID #:83

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SECOND JOINT STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT
131329.1
William A. Delgado (Bar No. 222666)
[e-mail]
Carlos A. Singer (Bar No. 236284)
[e-mail]
WILLENKEN WILSON LOH & DELGADO LLP
707 Wilshire Blvd., Suite 3850
Los Angeles, California 90017
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
WALGREEN CO.
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
MYMEDICALRECORDS, INC., a
Delaware corporation,
Plaintiff,
v.
WALGREEN CO., an Illinois
corporation,
Defendant.
Case No.: CV-13-9214-ODW (SHx)
SECOND JOINT STIPULATION TO
EXTEND TIME TO RESPOND TO
INITIAL COMPLAINT
Complaint Served: Jan. 2, 2014
Initial response date: Jan. 23, 2014
Current response date: Feb. 6, 2014
New response date: Feb. 20, 2014
Assigned to the Hon. Otis D. Wright II
Pretrial Conference: Not yet set
Trial: Not yet set
Case 2:13-cv-09214-ODW-SH Document 21 Filed 02/04/14 Page 1 of 5 Page ID #:83
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SECOND JOINT STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT
1
131329.1
This Second Joint Stipulation Extending the Time to Respond to Plaintiff’s
Complaint is made and entered into by and between Plaintiff MyMedicalRecords,
Inc. (“MMR”) and Defendant Walgreen Co. (“Walgreens”), by and through their
respective counsel, with reference to the following facts:
A. Whereas, on January 2, 2014, Plaintiff served its complaint on
Walgreens.
B. Whereas, the parties were continuing discussions regarding a
potential settlement or early resolution of this matter.
C. Whereas, the parties earlier agreed to extend Walgreens’ time to
respond to the complaint by fourteen (14) days from January 23, 2014 to February
6, 2014.
D. Whereas, the parties have satisfactorily concluded discussions
regarding the major deal points for a potential settlement of this matter.
E. Whereas, the parties now intend to move forward with the drafting of
a settlement agreement.
F. Whereas, the parties have agreed to a continuance of an additional
two weeks to February 20, 2014 for Walgreens to respond to the Complaint in this
matter so that the parties can focus on the drafting of the settlement agreement;
and
G. Whereas, the continuance of an additional two weeks would still
require Walgreens to respond to the Complaint within 30 days of January 23,
2014, the date on which the response was originally due.
//
//
Case 2:13-cv-09214-ODW-SH Document 21 Filed 02/04/14 Page 2 of 5 Page ID #:84
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SECOND JOINT STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT
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131329.1
NOW, THEREFORE, Plaintiff and Walgreens hereby stipulate, pursuant to
Local Rule 8-3, by and through their respective counsel, that Walgreens shall have
until and including February 20, 2014 to respond to the Complaint in this matter.
Respectfully submitted,
Dated: February 4, 2014 WILLENKEN WILSON LOH &
DELGADO LLP
By: /s/William A. Delgado
William A. Delgado
Attorneys for Defendant
WALGREEN CO.
Dated: February 4, 2014 LINER LLP
By: /s/Ted S. Ward*
Ted S. Ward
Attorneys for Plaintiff
MyMedicalRecords, Inc.
* By authorization
Case 2:13-cv-09214-ODW-SH Document 21 Filed 02/04/14 Page 3 of 5 Page ID #:85
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SECOND JOINT STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT
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131329.1
Signature Certification
Pursuant to Section 2(f)(4) of the Electronic Case Filing Administrative
Policies and Procedures Manual and Rule 5-4.3.4 (a)(2) of the United States
District Court for the Central District of California Local Rules, I hereby certify
that the content of this document is acceptable to Ted S. Ward, counsel for Plaintiff
MyMedicalRecords, Inc., and that I have obtained Mr. Ward’s authorization to
affix his electronic signature to this document.
Dated: February 4, 2014 WILLENKEN WILSON LOH &
DELGADO LLP
By: /s/William A. Delgado
William A. Delgado
Attorneys for Defendant
WALGREEN CO.
Case 2:13-cv-09214-ODW-SH Document 21 Filed 02/04/14 Page 4 of 5 Page ID #:86
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SECOND JOINT STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT
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131329.1
CERTIFICATE OF SERVICE
I hereby certify that I electronically filed the foregoing with the Clerk of the
Court using the CM/ECF system which will send notification of such filing to the
Electronic Service List for this Case.
Dated: February 4, 2014 WILLENKEN WILSON LOH &
DELGADO LLP
By: /s/William A. Delgado
William A. Delgado
Attorneys for Defendant
WALGREEN CO.