Handy v. LogMeIn, Inc.

Filing 62

ORDER GRANTING 61 Stipulation Setting Schedule for Response to Third Amended Complaint, signed by Magistrate Judge Jennifer L. Thurston on 9/23/2015. Response to Third Amended Complaint due by 10/21/2015. Briefing Schedule re: anticipated motion to dismiss: opposition due by 11/18/2015; reply due by 12/7/2015; hearing set for 12/14/2015 at 08:30 AM. (Hall, S)

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1 2 3 4 5 6 LATHAM & WATKINS LLP William Trach (pro hac vice) william.trach@lw.com John Hancock Tower, 27th Floor 200 Clarendon Street Boston, Massachusetts 02116 Telephone: (617) 948-6000 Facsimile: (617) 948-6001 12 LATHAM & WATKINS LLP Brian T. Glennon (SBN 211012) brian.glennon@lw.com James H. Moon (SBN 268215) james.moon@lw.com Alexandra Y. Welch (SBN 302394) alexandra.welch@lw.com 355 South Grand Avenue Los Angeles, California 90071 Telephone: (213) 485-1234 Facsimile: (213) 891-8763 13 Attorneys for Defendant LogMeIn, Inc. 7 8 9 10 11 14 UNITED STATES DISTRICT COURT 15 EASTERN DISTRICT OF CALIFORNIA 16 17 DARREN HANDY, No. 1:14-cv-01355-JLT 18 Plaintiff, 19 20 21 22 v. STIPULATION AND [PROPOSED] ORDER SETTING SCHEDULE FOR RESPONSE TO THIRD AMENDED COMPLAINT LOGMEIN, INC., (Doc. 61) Defendant. 23 24 25 26 27 28 ATTORNEYS AT LAW LOS AN GE LES STIPULATION & PROPOSED ORDER 1 2 3 4 5 6 7 8 9 10 TO THE HONORABLE COURT: Plaintiff Darren Handy (“Plaintiff”) and Defendant LogMeIn, Inc. (“Defendant”), by and through their respective undersigned counsel, hereby stipulate and agree as follows: WHEREAS, Plaintiff filed and served his Third Amended Complaint on September 18, 2015 (ECF No. 60); WHEREAS, Defendant’s current deadline to respond to the Second Amended Complaint is October 5, 2015 (Fed. R. Civ. P. 15(a)(3), 6(d)); WHEREAS, Defendant is in the process of investigating and conferring with its counsel regarding Plaintiff’s allegations in the Third Amended Complaint; WHEREAS, the parties wish to set a briefing schedule that is mutually agreeable for the 11 parties, and convenient for the Court, on Defendant’s anticipated motion to dismiss Plaintiff’s 12 Third Amended Complaint; 13 14 15 WHEREAS, counsel for Defendant has cleared a hearing date on its anticipated motion to dismiss for December 16, 2015 with the clerk of the Court; WHEREAS, Local Rule 144(a) provides that initial stipulations extending time for no 16 more than twenty-eight days to respond to a complaint may be filed without approval of the 17 Court if signed by all parties how have appeared in the action and are affected thereby; and 18 19 WHEREAS, this is the first extension of time with respect to the matters for which this extension is sought (see L.R. 144(b)); 20 IT IS HEREBY STIPULATED and agreed by and between the parties as follows: 21 1. 22 23 24 25 26 Defendant’s deadline to respond to the Third Amended Complaint shall be extended until October 21, 2015 pursuant to Local Rule 144(a); 2. Plaintiff’s opposition brief to Defendant’s anticipated motion to dismiss shall be due on November 18, 2015; 3. Defendant’s reply brief in support of its anticipated motion to dismiss shall be due on December 9, 2015; 27 28 ATTORNEYS AT LAW LOS AN GE LES 1 STIPULATION & PROPOSED ORDER 1 4. The hearing on Defendant’s anticipated motion to dismiss shall be held on 2 December 16, 2015 at 9:30 a.m. at the Bakersfield Courthouse (or a time thereafter as most 3 convenient for the Court). 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Dated: September 22, 2015 Respectfully submitted, By /s/ James H. Moon LATHAM & WATKINS LLP William Trach (pro hac vice) william.trach@lw.com John Hancock Tower, 27th Floor 200 Clarendon Street Boston, Massachusetts 02116 Telephone: (617) 948-6000 Facsimile: (617) 948-6001 LATHAM & WATKINS LLP Brian T. Glennon (SBN 211012) brian.glennon@lw.com James H. Moon (SBN 268215) james.moon@lw.com Alexandra Y. Welch (SBN 302394) alexandra.welch@lw.com 355 South Grand Avenue Los Angeles, California 90071 Telephone: (213) 485-1234 Facsimile: (213) 891-8763 Attorneys for Defendant LogMeIn, Inc. 20 21 22 23 24 25 26 27 28 ATTORNEYS AT LAW LOS AN GE LES 2 STIPULATION & PROPOSED ORDER 1 Dated: September 22, 2015 2 By /s/ Adrian R. Bacon KAZEROUNI LAW GROUP, APC Abbas Kazerounian (SBN 249203) ak@kazlg.com Matthew M. Loker (SBN 279939) ml@kazlg.com 245 Fischer Avenue, Unit D1 Costa Mesa, CA 92626 Telephone: (800) 400-6808 Facsimile: (800) 520-5523 3 4 5 6 7 8 13 LAW OFFICES OF TODD M. FRIEDMAN, P.C. Todd M. Friedman (SBN 216752) tfriedman@attorneysforconsumers.com Adrian R. Bacon (SBN 280332) abacon@attorneysforconsumers.com 324 S. Beverly Dr., #725 Beverly Hills, CA 90212 Telephone: (877) 206-4741 Facsimile: (866) 633-0228 14 Attorneys for Plaintiff Darren Handy 9 10 11 12 15 16 17 ATTESTATION I certify that I obtained concurrence in the filing of this document from all parties whose electronic signatures appear above. 18 19 Dated: September 22, 2015 By: /s/ James H. Moon 20 21 22 23 24 25 26 27 28 ATTORNEYS AT LAW LOS AN GE LES 3 STIPULATION & PROPOSED ORDER 1 [PROPOSED] ORDER 2 Based upon the stipulation of counsel, the Court hereby orders as follows: 3 1. 4 5 6 7 8 9 10 Defendant’s deadline to respond to the Third Amended Complaint shall be extended until October 21, 2015 pursuant to Local Rule 144(a); 2. Plaintiff’s opposition brief to Defendant’s anticipated motion to dismiss shall be due on November 18, 2015; 3. Defendant’s reply brief in support of its anticipated motion to dismiss shall be due on December 71, 2015; 4. The hearing on Defendant’s anticipated motion to dismiss shall be held on December 14, 2015 at 8:30 a.m. at the Bakersfield Courthouse. 11 12 13 IT IS SO ORDERED. Dated: September 23, 2015 /s/ Jennifer L. Thurston UNITED STATES MAGISTRATE JUDGE 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ATTORNEYS AT LAW LOS AN GE LES 1 The dates for the reply brief and the hearing have been modified by the Court. 4 STIPULATION & PROPOSED ORDER

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