Free Motion for Extension of Time to File Response/Reply - District Court of California - California

Case 3:08-cv-01110-DMS-BLM

Document 3

Filed 07/14/2008

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LYNN HUBBARD, III (CA SBN 69773) SCOTTLYNN J. HUBBARD, IV (CA SBN 212970) DISABLED ADVOCACY GROUP, APLC 12 Williamsburg Lane Chico, California 95926 Telephone: 530-895-3252 Facsimile: 530-894-8244 [email protected] Attorneys for Plaintiff BARBARA HUBBARD

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sd-433316 Case No. 08 CV 1110 DMS (BLM) JOINT MOTION FOR EXTENSION OF TIME

RICK BERGSTROM (CA SBN 169594) MORRISON & FOERSTER LLP 12531 High Bluff Drive, Suite 100 San Diego, California 92130-2040 Telephone: 858-720-5100 Facsimile: 858-720-5125 [email protected]

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

BARBARA HUBBARD, Plaintiff, v. JILL LINDSTEDT dba McDONALD'S #1557; McDONALD'S CORPORATION, Defendants.

Case No.

08 CV 1110 DMS (BLM)

JOINT MOTION FOR EXTENSION OF TIME FOR DEFENDANT MCDONALD'S CORPORATION TO FILE A RESPONSIVE PLEADING TO PLAINTIFFS' COMPLAINT

Case 3:08-cv-01110-DMS-BLM

Document 3

Filed 07/14/2008

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PLEASE TAKE NOTICE that plaintiff Barbara Hubbard ("plaintiff") and defendant McDonald's Corporation ("defendant"), hereby jointly move the Court for an order allowing defendant an extension of time in which to file a responsive pleading to plaintiffs' Complaint to and including August 14, 2008. Said extension of time is supported by good cause in that the additional time will permit defendant to gather further evidence regarding plaintiffs' allegations. Dated: July 14, 2008 DISABLED ADVOCACY GROUP, APLC

s/Lynn Hubbard, III_________________ Attorneys for Plaintiff Barbara Hubbard E-mail: [email protected] Dated: July 14, 2008 MORRISON & FOERSTER

s/Rick Bergstrom___________________ Attorneys for Defendant McDonald's Corporation E-mail: [email protected]

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sd-433316

Case No. 08 CV 1110 DMS (BLM) JOINT MOTION FOR EXTENSION OF TIME

Case 3:08-cv-01110-DMS-BLM

Document 3-2

Filed 07/14/2008

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RICK BERGSTROM (CA SBN 169594) MORRISON & FOERSTER LLP 12531 High Bluff Drive, Suite 100 San Diego, California 92130-2040 Telephone: 858-720-5100 Facsimile: 858-720-5125 [email protected] Attorneys for Defendant MCDONALD'S CORPORATION

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

BARBARA HUBBARD, Plaintiff, v. JILL LINDSTEDT dba McDONALD'S #1557; McDONALD'S CORPORATION, Defendants. I, Rick Bergstrom, declare:

Case No.

08 CV 1110 DMS (BLM)

PROOF OF SERVICE

I am employed in the City and County of San Diego, California. I am over the age of 18 years and not a party to the within action. My business address is 12531 High Bluff Drive, Suite 100, San Diego, CA 92130. On July 14, 2008 I caused the following documents to be served: JOINT MOTION FOR EXTENSION OF TIME FOR DEFENDANT MCDONALD'S CORPORATION TO FILE A RESPONSIVE PLEADING TO PLAINTIFFS' COMPLAINT

On all parties identified for Notice of Electronic Filing generated by the Court's CM/ECF system under the above-referenced case caption and number, including the parties identified below.

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sd-433552

Case No. 08 CV 1110 DMS (BLM) JOINT MOTION FOR EXTENSION OF TIME

Case 3:08-cv-01110-DMS-BLM

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Filed 07/14/2008

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Lynn Hubbard, III Scottlynn J. Hubbard, IV Disabled Advocacy Group APLC 12 Williamsburg Lane Chico, CA 95926 Tel: 530-895-3252 Fax: 530-894-8244 Attorneys for Plaintiff Barbara Hubbard In the following manner:

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sd-433552 Case No. 08 CV 1110 DMS (BLM) JOINT MOTION FOR EXTENSION OF TIME

_____(BY UNITED PARCEL SERVICE) I placed each such sealed envelope, to be collected at Morrison & Foerster, San Diego, California, following ordinary business practices. I am familiar with the practice of Morrison & Foerster for collection and processing of overnight packages, said practice being that in the ordinary course of business, overnight packages are picked up by a representative of that company to be sent that same day. ______(BY PERSONAL SERVICE) I caused such envelope to be personally served through World Wide Attorney Service, whose address is 701 B Street, Suite 324, San Diego, CA 92101. Proof of personal service will be filed upon receipt. __ (BY MAIL) I placed each such sealed envelope, with postage thereon fully prepaid for first-class mail, for collection and mailing at Morrison & Foerster, San Diego, California, following ordinary business practices. I am familiar with the practice of Morrison & Foerster for collection and processing of correspondence, said practice being that in the ordinary course of business, correspondence is deposited in the United States Postal Service the same day as it is placed for collection. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. _ (BY FACSIMILE) Pursuant to agreement of counsel, I transmitted the above documents by facsimile to the referenced facsimile number(s). X _ (BY NOTICE OF ELECTRONIC FILING) I delivered a true copy of the abovereferenced document(s) by Notice of Electronic Filing generated by the Court's CM/ECF system, pursuant to the Court's Local Rules, to the addressee(s) listed above. I declare under penalty of perjury under the laws of the State of California that this declaration was signed on July 14, 2008 at San Diego, California. s/Rick Bergstrom