LegalZoom.com Inc v. Rocket Lawyer Incorporated

Filing 84

Joint STIPULATION for Order To Take Certain Depositions After The Existing Discovery Cut-Off Date filed by Plaintiff LegalZoom.com Inc. (Attachments: # 1 Proposed Order)(Heather, Fred)

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PATRICIA L. GLASER -State Bar No. 55668
pglaser glaserweil.com
2 FRED .FATHER -State Bar No. 110650
flleather(a~glaserweil.com
3 GLASEI~ WEIL FINK HOWARD
AVCHEN & SHAPIRO LLP
4 10250 Constellation Boulevard, 19th Floor
Los Angeles, California 90067
s Telephone: [phone]
Facsimile: 310 556-2920
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Attorneys for Plaintiff
LegalZoom.com,Inc.
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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
Plaintiff,

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i6 ROCKET LAWYER INCORPORATED,
a Delaware corporation
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Defendant.
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Case No. 2:12-cv-09942-GAF-AGR
JOINT STIPULATION TO TAKE
CERTAIN DEPOSITIONS AFTER
THE EXISTING DISCOVERY
CUT-OFF DATE
Judge:
Courtroom:
Place:

Judge Gary A. Feess
740
255 East Templ~e St.
Los Angeles, CA
90012

Action Filed:

November 20, 2012

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JOINT STIPULATION TO TAKE CERTAIN DEPOSITIONS AFTER THE EXISTING DISCOVERY CUT-OFF
DATE
897695.3

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Defendant Rocket Lawyer Incorporated ("Rocket Lawyer")and Plaintiff

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LegalZoom,Inc.("LegalZoom"), by and through their respective counsel of record,

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hereby agree and stipulate as follows:

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1.

LegalZoom filed its original Complaint on November 20, 2012.

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2.

On or about Apri19, 2013,the parties agreed to mediate the case and

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agreed to stay all discovery deadlines pending mediation.

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On April 10, 2013,the Court entered an order staying discovery pending

s mediation.
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On April 11, 2013, the Court entered its Case Management and

io ~ Scheduling Order in this case.
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Beginning in April of 2013 and continuing up to August 22, 2013, the

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parties engaged in good faith efforts to mediate and settle this action with the

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assistance of a mediator. On August 22, 2013, after a final exchange of settlement

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demands,the parties decided to terminate the mediation effort. Discovery remained

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stayed throughout the negotiation period.

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On October 6, 2013, the Court entered an order granting the parties' joint

1~ stipulation to continue the trial and discovery dates set in the Court's April 11, 2013
is Scheduling Order. As a result, the discovery cut-off for this case was set for.April 7,
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2014.
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On January 22, 2014,the Court entered an order granting the parties'

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joint stipulation to continue the trial and discovery dates set in the Court's October 6,

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2013 Scheduling Order. As a result, the discovery cut-off for this case was set for

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~ June 24, 2014.

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8.

On April 15, 2014, the Court entered an order granting LegalZoom's ex

2s parte application to continue the trial and related dates set in the Court's January 22,
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2014 Scheduling Order. As a result, the discovery cut-off for this case was set for

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~ August 12, 2014.

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JOINT STIPULATION TO TAKE CERTAIN DEPOSITIONS AFTER THE EXISTING DISCOVERY CUT-OFF
DATE
897695.3

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including the production of documents and third-party discovery.
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Since October 2013, the parties have been engaging in discovery,

The parties have also recently filed cross- Motions for Summary

Judgment, with reply briefs due August 4, 2014, and a hearing set for August 18,

s 12014.
11.

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The parties wish to schedule and take approximately twelve(12)

depositions between them once all the documents have been produced. Based on the
s schedule of witnesses and counsel, there is not adequate time to schedule and
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complete those twelve depositions prior to the August 12, 2014 discovery cut-off

io date. Early August is a popular vacation week, and several key witnesses are
ii unavailable during that time. Permitting these depositions after August 12, 2014, will
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not affect any ofthe remaining dates from the Court's April 15, 2014 Order.

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BASED ON THE ABOVE,Rocket Lawyer and LegalZoom hereby stipulate

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is and agree, subject to Court approval, to permit the following twelve depositions to be
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taken after the Discovery Cut-Off, and on or before September 5, 2014, with the one

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exception being Dan Nye, whose deposition may be taken on or before September 12,

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2014:

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Deponent
Rocket Lawyer 30(b)(6)
De osition
Charle Moore
Paul Hollerbach
Dan N e
Alisa Weiner

Party Taking
De osition
LegalZoom
Le alZoom
Le alZoom
Le alZoom
LegalZoom

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2s
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Pete Franco
David Ba a
LegalZoom 30(b)(6)
Deposition

Le alZoom
Le alZoom
Rocket Lawyer

Scott MacDonell

Rocket La

er

JOINT STIPULATION TO TAKE CERTAIN DEPOSITIONS AFTER THE EXISTING DISCOVERY CUT-OFF
DATE
897695.3

Party Taking
De osition
Rocket Lawyer
Rocket La er
Rocket La er

Deponent

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Brian Liu
Dorian Quis e
Travis Gi

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IT IS SO STIPULATED:
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Dated: July 28, 2014
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Michael T. Jones(SBN 290660)
[e-mail]
GOODWIN PROCTER LLP
135 Commonwealth Drive
Menlo Park, California 94025-1105
Tel.: [phone]
Fax.: [phone]

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By:/s/Hong-An Vu(with permission)
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]

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Attorneysfor Defendant
ROCKET LAWYER INCORPORATED

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Dated: July 28, 2014

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By: /s/ Fred D. Heather
Patricia L. Glaser
pglaser@glaser~weil.com
Fred D. Heather
[e-mail]
GLASER WEIL FINK JACOBS
HOWARD AVCHEN & SHAPIRO
LLP
10250 Constellation Boulevard,
19th Floor

JOINT STIPULATION TO TAKE CERTAIN DEPOSITION
DATE
897695.3

CUT-OFF

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Tel.:[phone]
Fax.:[phone]

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Attorneysfor Plaintiff
LEGALZOOM.COM,INC.

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JOINT STIPULATION TO TAKE CERTAIN DEPOSITIONS AFTER THE EXISTING DISCOVERY CUT-OFF
DATE
897695.3

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CERTIFICATE OF SERVICE

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STATE OF CALIFORNIA,COUNTY OF LOS ANGELES

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I am employed in the County of Los Angeles, State of California; I am over the
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age of 18 and not a party to the within action; my business address is 10250
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Constellation Boulevard, 19th Floor, Los Angeles, California 90067.
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On July 28, 2014,I electronically filed the following documents) using the
CM/ECF system.
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JOINT STIPULATION TO CONTINUE THE TRIAL AND DISCOVERY
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DATES SET IN THE COURT'S OCTOBER 6,2013 ORDER FOR GOOD
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CAUSE
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Participants in the case are registered CM/ECF users and will be served by the
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CMIECF system.

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I declare that I am employed in the office of a member of the bar of this court at

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whose direction the service was made. I declare under penalty of perjury that the

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above is true and correct.
Executed on July 28, 2014at Los Angeles, California.

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/s/ Fred Heather
Fred Heather

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CERTIFICATE OF SERVICE
897695.3