None of the Defendants have appeared in this case to date and/or responded

to the Complaint as noted above. Since the last motion was filed and particularly

in the month of March 2013, some or all of the parties via their counsel and/or

Case 3:12-cv-02997-CAB-WVG Document 27 Filed 03/28/13 Page 3 of 5EX PARTE MOTION TO EXTEND TIME FOR ALL DEFENDANTS

TO RESPOND TO COMPLAINT CASE NO. 3:12-CV-02997- CAB-WVG

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HANDAL & ASSOCIATES

1200 THIRD AVE

SUITE 1321

SAN DIEGO, CA 92101

TEL: 619.544.6400

FAX: 619.696.0323

apparent authorized agents, have been actively engaged in discussions regarding

the possible global resolution of this case. It is believed that significant progress

has been made toward the possible resolution of this matter. However, the parties

need additional time within which to discuss such matters.

With the above in mind, Plaintiff seeks an extension of time for all the

Defendants to respond to the Complaint not for delay, but to permit the parties an

opportunity to resolve Plaintiff’s claims without the need for further litigation. If a

resolution can be reached in this matter, most likely such a resolution would be a

global resolution that would resolve this case in its entirety as to all the parti

None of the Defendants have appeared in this case to date and/or responded

to the Complaint as noted above. Since the last motion was filed and particularly

in the month of March 2013, some or all of the parties via their counsel and/or

Case 3:12-cv-02997-CAB-WVG Document 27 Filed 03/28/13 Page 3 of 5EX PARTE MOTION TO EXTEND TIME FOR ALL DEFENDANTS

TO RESPOND TO COMPLAINT CASE NO. 3:12-CV-02997- CAB-WVG

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HANDAL & ASSOCIATES

1200 THIRD AVE

SUITE 1321

SAN DIEGO, CA 92101

TEL: 619.544.6400

FAX: 619.696.0323

apparent authorized agents, have been actively engaged in discussions regarding

the possible global resolution of this case. It is believed that significant progress

has been made toward the possible resolution of this matter. However, the parties

need additional time within which to discuss such matters.

With the above in mind, Plaintiff seeks an extension of time for all the

Defendants to respond to the Complaint not for delay, but to permit the parties an

opportunity to resolve Plaintiff’s claims without the need for further litigation. If a

resolution can be reached in this matter, most likely such a resolution would be a

global resolution that would resolve this case in its entirety as to all the parti