LegalZoom.com Inc v. Rocket Lawyer Incorporated

Filing 207

Joint STIPULATION to Vacate Trial Date and Revising Schedule for Completing Discovery and Filing Summary Judgment Motions filed by Defendant Rocket Lawyer Incorporated. (Attachments: # 1 Proposed Order)(Jones, Michael)

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Forrest A. Hainline III (SBN 64166)
[e-mail]
Hong-An Vu (SBN 266268)
[e-mail]
GOODWIN PROCTER LLP
Three Embarcadero Center
24th Floor
San Francisco, California 94111
Tel.: [phone]
Fax.: [phone]
Michael T. Jones (SBN 290660)
[e-mail]
GOODWIN PROCTER LLP
135 Commonwealth Drive
Menlo Park, California 94025-1105
Tel.: [phone]
Fax.: [phone]
Brian W. Cook (Pro Hac Vice)
[e-mail]
GOODWIN PROCTER LLP
53 State Street
Boston, MA 02109-2802
Tel.: [phone]
Fax.: [phone]
Attorneys for Defendant
ROCKET LAWYER INCORPORATED

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA
WESTERN DIVISION
LEGALZOOM.COM, INC., a Delaware Case No. 2:12-cv-09942-GAF-AGR
corporation,
JOINT STIPULATION VACATING
Plaintiff,
TRIAL DATE AND REVISING
SCHEDULE FOR COMPLETING
v.
DISCOVERY AND FILING
SUMMARY JUDGMENT MOTIONS
ROCKET LAWYER
INCORPORATED, a Delaware
Judge:
Judge John E. McDermott
corporation,
Courtroom: 312 N. Spring Street,
Courtroom C, 8th Floor
Defendant.
Los Angeles, CA 90012
Action Filed: November 20, 2012

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985909.1

WHEREAS an order entered in this case on November 10, 2014 (the “Prior

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Order”), granted a stipulation of the parties to take additional limited discovery from

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each other and from third parties, including Google, Inc., as a means to supplement

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the record for purposes of briefing cross-motions for summary judgment;
WHEREAS the Prior Order required the close of additional limited discovery

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by January 16, 2015, a deadline to supplement the record of February 2, 2015, a

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hearing date on cross motions for summary judgment of February 23, 2015, and a

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trial date of April 21, 2015;
WHEREAS LegalZoom.com, Inc., represents that it (a) has been unable to

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complete all of the contemplated third party discovery necessary to supplement the

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record, (b) has on January 5, 2015, filed in the Northern District of California a

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motion to compel a document production by Google, Inc., and (c) contemplates at

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least one additional motion to compel deposition testimony by an employee of

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Google Ventures, named Michael Margolis, to be filed in the Western District of

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Washington;
WHEREAS the parties appeared at a case status conference on January 7,

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2015, to discuss the case schedule and the anticipated completion date for discovery

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from Google, Inc. and others;

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WHEREAS the Court suggested, and the parties agreed, that a new schedule

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for supplementing the record and hearing summary judgment motions be agreed to

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by the parties and submitted to the Court for approval.
THEREFORE, Plaintiff and counterclaim defendant LegalZoom.com, Inc.

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and defendant and counterclaimant Rocket Lawyer Incorporated hereby stipulate as

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follows:

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1.

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The parties shall appear before Magistrate Judge Segal for a Settlement

Conference on March 17, 2015.

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985909.1

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2.

The new deadline for completing additional discovery from third

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parties, which remains subject to the category and witness limits of the Prior Order,

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is May 19, 2015.

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3.

Upon learning that the completion of third party discovery is either not

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possible or very unlikely by the May19, 2015, deadline, counsel shall notify the

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opposing party and the Court, and may, no later than April 24, 2015, file a request

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seeking an additional extension of the deadlines provided by this stipulation and

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order.

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4.

Upon completing all third party discovery, the parties may submit new

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cross-motions for summary judgment (which will supersede prior summary

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judgment filings) on or before June 12, 2015.
5.

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Summary judgment reply briefs shall be due on or before July 17,

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A hearing to decide the summary judgment motions shall be held on

2015.

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Summary judgment opposition briefs shall be due on or before July 3,

6.

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2015.

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August 10, 2015, or as soon thereafter as the Court’s calendar permits. At that

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hearing, the Court shall also hear argument concerning the Rule 11 motion

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previously brought by LegalZoom and briefed by the parties.

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8.

One week after the hearing on summary judgment motions, the Court

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shall conduct a status conference at which a new trial date and new dates for all

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pretrial filings shall be set.
IT IS SO STIPULATED.

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985909.1

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Dated: January 13, 2015

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Respectfully submitted,
By: Michael T. Jones
Forrest A. Hainline III
[e-mail]
Hong-An Vu (SBN 266268)
[e-mail]
Michael T. Jones (SBN 290660)
[e-mail]
Brian W. Cook (Pro Hac Vice)
[e-mail]
GOODWIN PROCTER LLP
Three Embarcadero Center
24th Floor
San Francisco, California 94111
Tel.: [phone]
Fax.: [phone]

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Attorneys for Defendant
ROCKET LAWYER INCORPORATED

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Dated: January 13, 2015

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By: /s/Patricia L. Glaser
(with permission)
Patricia L. Glaser
[e-mail]
Fred D. Heather
[e-mail]
Aaron Allan
[e-mail]
GLASER WEIL FINK HOWARD
AVCHEN & SHAPIRO LLP
10250 Constellation Boulevard,
19th Floor
Los Angeles, California 90067
Tel.: [phone]
Fax.: [phone]
Attorneys for Plaintiff
LEGALZOOM.COM, INC.

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985909.1