Armas v. RealPage Inc

UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE LENA ARMAS and ANDREA BLUM, g individually and on behalf of all others NO. 2:22-cv-01726 RSL similarly situated, 9 Plaintiff STIPULATED MOTION AND auntirt, ORDER SUSPENDING DEADLINE 10 FOR DEFENDANT AVENUES5 Vv. RESIDENTIAL, LLC TO 11 REALPAGE, INC., GREYSTAR REAL RESPOND TO COMPLAINT ESTATE PARTNERS, LLC, CH REAL 12 ESTATE SERVICES, LLC, LINCOLN PROPERTY CoO., FPIMANAGEMENT, INC., MID-AMERICA APARTMENT 13 COMMUNITIES, INC., AVENUES RESIDENTIAL, LLC, EQUITY 14 RESIDENTIAL, ESSEX MANAGEMENT CORPORATION, AVALONBAY 15 COMMUNITIES, INC., CAMDEN PROPERTY TRUST, ESSEX PROPERTY TRUST, INC., THRIVE COMMUNITIES 16 MANAGEMENT, LLC, SECURITY PROPERTIES INC., B/T WASHINGTON, 17 LLC d/b/a BLANTON TURNER, INDEPENDENCE REALTY TRUST, INC., 18 CUSHMAN & WAKEFIELD, INC., BH MANAGEMENT SERVICES, LLC, and UDR, INC., Defendants.

24 || STIPULATED MOTION AND ORDER SUSPENDING Ashbaugh Beal DEADLINE FOR DEFENDANT AVENUES 701 FIFTH AVE., SUITE 4400 RESIDENTIAL, LLC TO RESPOND TO COMPLAINT - 1 SEAT TLE, WA 98104 [2:22-ev-01726 RSL] T. 206.386.5900 F. 206.344.7400 Pursuant to Local Civil Rules 7(d)(1), 7q), and 10(g), Plaintiffs Lena Armas and || Andrea Blum (collectively, “Plaintiffs”) and Defendant Avenue5 Residential, LLC, by and || through their respective counsel, hereby stipulate as follows: 4 WHEREAS, Plaintiffs filed a Class Action Complaint (the “Complaint”) on December 6, 2022. ECF No. 1; ‘ WHEREAS, Plaintiffs and certain other Defendants (“Stipulating Defendants”) entered a Stipulation that, for purposes of judicial efficiency, would temporarily suspend the date for ’ a responsive pleading to the Complaint; 8 WHEREAS, the Court subsequently entered an Order [ECF No. 54] that, inter alia, suspended the date for the Stipulating Defendants to respond to the Complaint, and required || the parties to submit a status report by January 18, 2023;' and 11 WHEREAS, Plaintiffs and Defendant Avenue5S Residential believe that judicial D efficiency would be served by suspending the date for AvenueS Residential to move, answer or otherwise respond to the Complaint, and to participate in the joint status report.

In making this stipulation, AvenueS Residential does not waive, in this or any other "4 action, any (i) defenses or arguments for dismissal that may be available under Fed. R. Civ. P. 12; (11) affirmative defenses under Fed. R. Civ. P. 8; (111) other statutory or common law || defenses that may be available; or (iv) right to seek or oppose any reassignment, transfer, or || consolidated alternatives.

18 THEREFORE, Plaintiffs and Defendant AvenueS Residential, LLC stipulate and agree to suspend the deadline for AvenueS Residential, LLC to answer, move to dismiss, or otherwise respond to the Complaint and request that the Court enter the proposed order pursuant to this stipulation.

Substantially identical stipulations have been entered by this Court in Navarro v. RealPage, Inc. et al., No. 2:22- ev-01552 (W.D. Wash.); Alvarez et al. v. RealPage, Inc. et al., No. 2:22-cv-01617 (W.D. Wash.); and Cherry et al. v. RealPage, Inc. et al., No. 2:22-cv-01618 (W.D. Wash.).

24 || STIPULATED MOTION AND ORDER SUSPENDING Ashbaugh Beal DEADLINE FOR DEFENDANT AVENUES Zou rT AVE. SUITE 4400 13:39-ev-01736 RSL] TO RESPOND TO COMPLAINT - 2 en Sena AG RAATAGS STIPULATED to this 6th day of January, 2023.

3 HAGENS BERMAN SOBOL SHAPIRO LLP BAKER BoTTs LLP s/ Steve W. Berman s/ James Kress Steve W. Berman (WSB No. 12536) James Kress (pro hac vice forthcoming) [email protected] [email protected] Breanna Van Engelen (WSB No. 49213) Paul Cuomo [email protected] [email protected] 1301 Second Avenue, Suite 2000 700 K. Street, NW Seattle, WA 98101 Washington, DC 20001 Telephone: (206) 623-7292 Telephone: (202) 639-7884 Counsel for Plaintiffs Lena Armas and Andrea Danny David (pro hac vice forthcoming) Blum Individually and on Behalf of All Others [email protected] Similarly Situated BAKER BoTTs LLP 10 910 Louisiana Street Houston, Texas 77002 Telephone: (713) 229-4055 Counsel for Defendant Avenue5 Residential, LLC B ASHBAUGH BEAL LLP s/ Rebecca S. Ashbaugh Rebecca S. Ashbaugh, WSBA #38186 [email protected] 5“ Avenue, Suite 4400 Seattle, WA 98104 Telephone: (206) 386-5900 M Counsel for Defendant Avenue5 Residential, LLC || STIPULATED MOTION AND ORDER SUSPENDING Ashbaugh Beal DEADLINE FOR DEFENDANT AVENUES 701 FIFTH AVE., SUITE 4400 RESIDENTIAL, LLC TO RESPOND TO COMPLAINT - 3 Ee ee [2:22-cv-01726 RSL] T. 206.386.5900 F. 206.344.7400 1 ORDER 2 THIS MATTER came before the Court on the parties’ Stipulated Motion to Suspend the Deadline for Defendant Avenue5 Residential, LLC to Respond to the Complaint. Now, therefore, IT IS HEREBY ORDERED THAT: > Consistent with this Court’s Order of December 27, 2022 [ECF No. 54], the deadline || for Defendant AvenueS Residential, LLC to answer, move to dismiss, or otherwise respond to || the Complaint is hereby suspended. g Defendant Avenue5 Residential, LLC shall meet and confer with Plaintiffs, and participate in the filing of the joint status report, as covered by the Court’s prior Order, due on January 18, 2023.

11 Dated this 9th day of January, 2023.

MUS Garcnaike 13 Robert S. Lasnik 4 United States District Judge || STIPULATED MOTION AND ORDER SUSPENDING Ashbaugh Beal DEADLINE FOR DEFENDANT AVENUES Zou rT AVE. SUITE 4400 13:39-ev-01736 RSL] TO RESPOND TO COMPLAINT - 4 en Sena AG RAATAGS