Levitte v. Google Inc.

Filing 43

STIPULATION CONTINUING DEADLINE FOR FILING THE CONSOLIDATED AMENDED COMPLAINT AND DEFENDANTS RESPONSE TO CONSOLIDATED AMENDED COMPLAINT by Hal K. Levitte. (Jonckheer, Willem) (Filed on 3/31/2009)

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Levitte v. Google Inc. Doc. 43 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ROBERT C. SCHUBERT S.B.N. 62684 WILLEM F. JONCKHEER S.B.N. 178748 DUSTIN L. SCHUBERT S.B.N. 254876 SCHUBERT JONCKHEER KOLBE & KRALOWEC LLP Three Embarcadero Center, Suite 1650 San Francisco, California 94111 Telephone: (415) 788-4220 Lead Counsel for Plaintiffs IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION In re Google AdWords Litigation CASE NO. C 08-03369 JW HON. JAMES WARE STIPULATION CONTINUING DEADLINE FOR FILING THE CONSOLIDATED AMENDED COMPLAINT AND DEFENDANT'S RESPONSE TO CONSOLIDATED AMENDED COMPLAINT Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION Plaintiffs and defendant Google Inc. ("Google"), by and through their respective counsel, stipulate and agree as follows: WHEREAS, on February 25, 2009, the Court issued (1) an Order Granting Motion to Consolidate and Appointing Interim Lead Counsel, and (2) a Scheduling Order for Class Discovery ("the Scheduling Order") in this action; WHEREAS, pursuant to the Scheduling Order, the current deadline for filing the Consolidated Amended Complaint is April 6, 2009, and the deadline for defendant to file an answer or otherwise respond to the Consolidated Amended Complaint is April 30, 2009; WHEREAS, based upon certain matters that have arisen in connection with the schedule of plaintiffs' lead counsel, plaintiffs have requested, and defendant has agreed to, a short extension of the deadline to file the Consolidated Amended Complaint to April 24, 2009, with a corresponding change to Google's deadline to file an answer or otherwise respond to the Consolidated Amended Complaint to May 18, 2009; WHEREAS, Google's response to the complaint in JIT Packaging, Inc. v. Google Inc., Case No. 08-04701 JW (administratively closed upon consolidation), one of the four consolidated actions, is currently due on April 6, 2009 (See Docket No. 42), and Google's response would have been mooted by the filing of the Consolidated Amended Complaint on that date absent the agreed to extension of the deadline to file the Consolidated Amended Complaint to April 24, 2009; WHEREAS, this is plaintiffs' first request for an extension, and the remaining deadlines set by the Scheduling Order remain in effect; NOW THEREFORE, the parties hereby stipulate, and request the Court to order, that (a) the deadline for the Consolidated Amended Complaint be extended to April 24, 2009; (b) the deadline for Google to file an answer or otherwise respond to the Consolidated Amended Complaint be correspondingly changed to May 18, 2009; and (c) Google need not file a separate response to the JIT Packaging complaint, which will be superseded by the filing of the Consolidated Amended Complaint. Stipulation Continuing Deadline for Filing the Consolidated Amended Complaint and Defendant's Answer to Consolidated Amended Complaint 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: March 27, 2009 SCHUBERT JONCKHEER KOLBE & KRALOWEC LLP By: /s/Willem F. Jonckheer Willem F. Jonckheer ROBERT C. SCHUBERT WILLEM F. JONCKHEER KIMBERLY A. KRALOWEC DUSTIN L. SCHUBERT Lead Counsel for Plaintiffs COOLEY GODWARD KRONISH LLP MICHAEL G. RHODES (116127) LEO P. NORTON (216282) PETER J. WILLSEY (pro hac vice) By: /s/Leo P. Norton Leo P. Norton Counsel for Defendant ATTESTATION OF FILER I, Willem F. Jonckheer, hereby attest that concurrence in the filing of the document has been obtained from each of the other signatories. Dated: March 27, 2009 SCHUBERT JONCKHEER KOLBE & KRALOWEC LLP By: /s/Willem F. Jonckheer Willem F. Jonckheer Lead Counsel for Plaintiffs Stipulation Continuing Deadline for Filing the Consolidated Amended Complaint and Defendant's Answer to Consolidated Amended Complaint 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Stipulation Continuing Deadline for Filing the Consolidated Amended Complaint and Defendant's Answer to Consolidated Amended Complaint 3 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION In re Google AdWords Litigation CASE NO. C 08-03369 JW HON. JAMES WARE ORDER GRANTING STIPULATION CONTINUING DEADLINE FOR FILING THE CONSOLIDATED AMENDED COMPLAINT AND DEFENDANT'S RESPONSE TO CONSOLIDATED AMENDED COMPLAINT ORDER Pursuant to the parties' stipulation (Docket Number 43), and good cause appearing: (1) the deadline for plaintiffs to file the Consolidated Amended Complaint is hereby extended to April 24, 2009; (2) the deadline for Google to file an answer or otherwise respond to the Consolidated Amended Complaint is hereby correspondingly changed to May 18, 2009; and (3) Google need not file a separate response to the JIT Packaging complaint, which will be superseded by the filing of the Consolidated Amended Complaint. Dated: ____________________________________ Hon. James Ware