Wood et al v. Motorola Mobility, Inc.

Filing 24

ORDER EXTENDING BRIEFING SCHEDULE ON MOTION TO DISMISS (tf, COURT STAFF) (Filed on 12/1/2011)

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CLINTON JUDD MCCORD
ERIN LEE JEANETTE PFAFF
EDWARDS WILDMAN PALMER LLP
9665 Wilshire Boulevard, Suite 200
Beverly Hills, CA 90212
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Defendant
Motorola Mobility, Inc.

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SEAN P. REIS (184044)
EDELSON MCGUIRE LLP
30021 Tomas Street, Suite 300
Rancho Santa Margarita, CA 92688
Telephone:
[phone]
Facsimile:
[phone]
Email: [e-mail]
RAFEY S. BALABANIAN (PHV)
CHRISTOPHER L. DORE (PHV)
EDELSON MCGUIRE LLC
350 North LaSalle Street, Suite 1300
Chicago, IL 60654
Telephone:
[phone]
Facsimile:
[phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Plaintiffs and Putative
Classes

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ELYSE WOOD and JACK HAUGHT,
individually, and on behalf of all others
similarly situated,

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Plaintiffs,

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v.

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MOTOROLA MOBILITY, INC., a Delaware
corporation,

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Defendant.

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STIPULATION
CV-11-04409-SI

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Case No. CV-11-04409-SI

JOINT STIPULATION
EXTENDING THE PARTIES’
BRIEFING SCHEDULE ON
DEFENDANT’S MOTION TO
DISMISS COMPLAINT

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Pursuant to Local Rule 6-1, Plaintiff Elyse Wood and Jack Haught, individually and

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on behalf of a class of similarly situated individuals (“Plaintiffs”), and Defendant Motorola

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Mobility, Inc. (collectively referred to herein as the “Parties”), by and through their

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respective counsel of record, hereby stipulate to modify the Parties’ briefing schedule as it

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pertains to Defendant’s Motion to Dismiss the Complaint as follows:

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WHEREAS, on September 2, 2011, Plaintiffs filed their Class Action Complaint
against Defendant.
WHEREAS, on October 24, 2011, the Parties’ stipulated to extend Defendant’s time
to respond to Plaintiff’s Complaint by twenty-one (21) days.
WHEREAS, on November 17, 2011, Defendant moved to dismiss Plaintiffs’
Complaint.
WHEREAS, Plaintiffs’ current deadline to respond to Defendant’s Motion to Dismiss
is December 1, 2011.
WHEREAS, in the interests of justice and in an effort to enhance judicial efficiency

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and preserve resources, the Parties have agreed to extend Plaintiffs’ time to oppose

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Defendant’s Motion to Dismiss as well as Defendant’s time to reply in support of its motion.

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WHEREAS, based on the foregoing, Plaintiffs have requested and Defendant has

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consented to extend Plaintiffs’ time to file their opposition to Defendant’s motion to

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December 12, 2011. The Parties have further agreed to extend Defendant’s deadline to file

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any reply brief to December 22, 2011.

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WHEREAS, this extension is not sought for any improper purpose.

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WHEREAS, the extension of time sought will not alter the date of any event or

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deadline already fixed by Court Order, including the hearing date on Defendant’s Motion to

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Dismiss.

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NOW, THEREFORE, THE PARTIES HEREBY STIPULATE and AGREE, subject
to the approval of the Court, that:

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STIPULATION
CV-11-04409-SI

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Plaintiff shall have until December 12, 2011, to file any opposition papers to

Defendant’s Motion to Dismiss;
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Defendant shall have until December 22, 2011, to file any reply papers in

support of its Motion to Dismiss.

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Respectfully submitted,

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EDWARDS WILDMAN PALMER LLP

Dated: November 30, 2011
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By:

/s/ Clinton J. McCord

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Attorneys for Defendant Motorola
Mobility, Inc.

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Dated: November 30, 2011

EDELSON MCGUIRE LLC

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By:

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/s/ Rafey S. Balabanian
Rafey S. Balabanian
Attorneys for Plaintiffs

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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DATED: November ____, 2011

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__________________________________
HONORABLE SUSAN ILLSTON
UNITED STATES DISTRICT JUDGE

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STIPULATION
CV-11-04409-SI

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