Handy v. LogMeIn, Inc.
Filing
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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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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
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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
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Attorneys for Defendant LogMeIn, Inc.
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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DARREN HANDY,
No. 1:14-cv-01355-JLT
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Plaintiff,
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v.
STIPULATION AND [PROPOSED]
ORDER SETTING SCHEDULE FOR
RESPONSE TO THIRD AMENDED
COMPLAINT
LOGMEIN, INC.,
(Doc. 61)
Defendant.
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ATTORNEYS AT LAW
LOS AN GE LES
STIPULATION & PROPOSED ORDER
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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
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parties, and convenient for the Court, on Defendant’s anticipated motion to dismiss Plaintiff’s
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Third Amended Complaint;
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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
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more than twenty-eight days to respond to a complaint may be filed without approval of the
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Court if signed by all parties how have appeared in the action and are affected thereby; and
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WHEREAS, this is the first extension of time with respect to the matters for which this
extension is sought (see L.R. 144(b));
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IT IS HEREBY STIPULATED and agreed by and between the parties as follows:
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1.
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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;
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ATTORNEYS AT LAW
LOS AN GE LES
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STIPULATION & PROPOSED ORDER
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4.
The hearing on Defendant’s anticipated motion to dismiss shall be held on
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December 16, 2015 at 9:30 a.m. at the Bakersfield Courthouse (or a time thereafter as most
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convenient for the Court).
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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.
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ATTORNEYS AT LAW
LOS AN GE LES
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STIPULATION & PROPOSED ORDER
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Dated: September 22, 2015
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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
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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
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Attorneys for Plaintiff Darren Handy
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ATTESTATION
I certify that I obtained concurrence in the filing of this document from all parties whose
electronic signatures appear above.
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Dated: September 22, 2015
By: /s/ James H. Moon
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ATTORNEYS AT LAW
LOS AN GE LES
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STIPULATION & PROPOSED ORDER
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[PROPOSED] ORDER
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Based upon the stipulation of counsel, the Court hereby orders as follows:
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1.
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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.
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IT IS SO ORDERED.
Dated:
September 23, 2015
/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE
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ATTORNEYS AT LAW
LOS AN GE LES
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The dates for the reply brief and the hearing have been modified by the Court.
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STIPULATION & PROPOSED ORDER
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