LegalZoom.com Inc v. Rocket Lawyer Incorporated

Filing 64

STIPULATION for Order RE SUMMARY JUDGMENT BRIEFING filed by Defendant Rocket Lawyer Incorporated. (Attachments: # 1 Proposed Order)(Vu, Hong-An)

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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

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WESTERN DIVISION

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LEGALZOOM.COM, INC., a Delaware
corporation,

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Plaintiff,
v.
ROCKET LAWYER
INCORPORATED, a Delaware
corporation,

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Defendant.

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ACTIVE/74060355.1

Case No. 2:12-cv-09942-GAF-AGR
STIPULATION RE SUMMARY
JUDGMENT BRIEFING
SCHEDULE
Judge:
Courtroom:

Judge Gary A. Feess
740
255 East Temple Street
Los Angeles, CA 90012
Action Filed: November 20, 2012

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Plaintiff LegalZoom.com Inc. (“LegalZoom”) and defendant Rocket Lawyer
Incorporated (“Rocket Lawyer”) stipulate and agree as follows:
1.

On June 17, 2014, Rocket Lawyer initiated the meet and confer process

for its motion for summary judgment pursuant to Local Rule 7-3.
2.

On June 20, 2014, the parties met and conferred about Rocket Lawyer’s

motion for summary judgment and a proposed briefing schedule.
3.

On June 25, 2014, LegalZoom agreed to Rocket Lawyer’s proposed

hearing date and briefing schedule as detailed below.
4.

Also on June 25, 2014, LegalZoom initiated a meet and confer with

Rocket Lawyer regarding its motion for partial summary judgment.
5.

On June 27, 2014, the parties met and conferred regarding

LegalZoom’s motion for partial summary judgment.
6.

On July 1, 2014, Rocket Lawyer agreed to a briefing schedule proposed

by LegalZoom as detailed below.
7.

The schedule agreed to by the parties for the cross-motions for

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summary judgment ensure that all briefing is submitted to the Court at least fourteen

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days before the August 18, 2014 hearing date pursuant to Local Rule 7-10.

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NOW, WHEREFORE, Rocket Lawyer and LegalZoom stipulate and agree to
the following briefing schedule for their cross-motions for summary judgment:

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Deadline

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Date

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Rocket Lawyer to file Motion for Summary Judgment

June 30, 2014

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LegalZoom to file Motion for Partial Summary Judgment

July 14, 2014

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LegalZoom’s Opposition to Rocket Lawyer’s Motion for

July 21, 2014

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Summary Judgment

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Rocket Lawyer’s Opposition to LegalZoom’s Motion for

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Partial Summary Judgment

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ACTIVE/74060355.1

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July 28, 2014

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Deadline

Date

Rocket Lawyer’s Reply in support of its Motion for

August 4, 2014

Summary Judgment
LegalZoom’s Reply in support of its Motion for Partial

August 4, 2014

Summary Judgment
Date of hearing on cross-motions

August 18, 2014 at

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9:30 a.m.

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Dated: July 11, 2014

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Respectfully submitted,
By:

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/s/Hong-An Vu
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]

Attorneys for Defendant
ROCKET LAWYER INCORPORATED

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ACTIVE/74060355.1

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Dated: July 11, 2014

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Respectfully submitted,
By: /s/Fred D. Heather (with permission)
Patricia L. Glaser
[e-mail]
Fred D. Heather
[e-mail]
Mary Ann T. Nguyen
[e-mail]
GLASER WEIL FINK JACOBS
HOWARD AVCHEN & SHAPIRO

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LLP

10250 Constellation Boulevard, 19th
Floor
Los Angeles, California 90067
Tel. [phone]
Fax. [phone]

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Attorneys for Plaintiff
LEGALZOOM.COM, INC.

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ACTIVE/74060355.1

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PROOF OF SERVICE

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I am employed in the County of Los Angeles, State of California. I am over
the age of 18 and not a party to the within action. My business address is: 601 S.
Figueroa Street, 41st Floor, Los Angeles, CA 90017-5704
On July 11, 2014, I served the following documents by placing a true copy
thereof in a sealed envelope(s) on the persons below as follows:
STIPULATION RE SUMMARY JUDGMENT BRIEFING SCHEDULE
Counsel for
Plaintiff LegalZoom.com, Inc.
Tel. [phone]
Fax. [phone]
[e-mail]
[e-mail]
[e-mail]

Patricia L. Glaser
Fred D. Heather
Mary Ann T. Nguyen
GLASER WEIL FINK JACOBS
HOWARD AVCHEN & SHAPIRO LLP
10250 Constellation Boulevard, 19th
Floor
Los Angeles, California 90067

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

*(OVERNIGHT DELIVERY). By overnight delivery. I enclosed the
documents in an envelope or package provided by an overnight delivery
carrier and addressed to the persons at the addresses listed. I placed the
envelope or package for collection and overnight delivery at an office or a
regularly utilized drop box of the overnight delivery carrier.



(CM/ECF Electronic Filing) I caused the above document(s) to be
transmitted to the office(s) of the addressee(s) listed above by electronic
mail at the e-mail address(es) set forth above pursuant to
Fed.R.Civ.P.5(d)(1). “A Notice of Electronic Filing (NEF) is generated
automatically by the ECF system upon completion of an electronic filing.
The NEF, when e-mailed to the e-mail address of record in the case, shall
constitute the proof of service as required by Fed.R.Civ.P.5(d)(1). A copy
of the NEF shall be attached to any document served in the traditional
manner upon any party appearing pro se.”

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I declare under penalty of perjury that I am employed in the office of a
member of the bar of this Court at whose direction this service was made and that
the foregoing is true and correct.
Executed on July 11, 2014, at Los Angeles, California.

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Kemi Oyemade
(Type or print name)

(Signature)

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ACTIVE/74060355.1

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