Granfield v. NVIDIA Corporation

Filing 50

STIPULATION AND ORDER, Motions terminated: 49 Plaintiffs deadline for filing its response to NVIDIAs Motion to Dismiss shall be extended to May 11, 2012, and that NVIDIAs deadline for filing its reply in support of its Motion shall be extended to May 25, 2012.. Signed by Judge James Ware on 4/24/12. (tdm, COURT STAFF) (Filed on 4/24/2012)

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ROBERT P. VARIAN (SBN 107459)
Email: [e-mail]
JAMES N. KRAMER (SBN 154709)
Email: [e-mail]
JUSTIN M. LICHTERMAN (SBN 225734)
Email: [e-mail]
ALEXANDER K. TALARIDES (SBN 268068)
Email: [e-mail]
ORRICK, HERRINGTON & SUTCLIFFE LLP
The Orrick Building
405 Howard Street
San Francisco, CA 94105-2669
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant
NVIDIA CORPORATION

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EDWARD F. HABER (pro hac vice)
Email: [e-mail]
MICHELLE BLAUNER
Email: [e-mail]
IAN J. McLOUGHLIN
Email: [e-mail]
SHAPIRO HABER & URMY LLP
53 State Street
Boston, MA 02109
Telephone: [phone]
Facsimile: [phone]
ROBERT C. SCHUBERT (SBN 62684)
Email: [e-mail]
JASON A. PIKLER (SBN 245722)
Email: [e-mail]
SCHUBERT JONCKHEER & KOLBE LLP
Three Embarcadero Center, Suite 1650
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff and the
Putative Class and Subclasses

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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MONICA GRANFIELD, Individually and on
Behalf of All Others Similarly Situated,

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Plaintiff,
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v.
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NVIDIA Corporation,
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Defendant.
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Case No. 3:11-cv-05403-JW
STIPULATION AND [PROPOSED]
ORDER EXTENDING DEADLINES
FOR RESPONSE AND REPLY
BRIEFS REGARDING NVIDIA’S
PENDING MOTION TO DISMISS
[CIVIL LOCAL RULE 6-2]
Date:
June 11, 2012
Time: 9:00 A.M.
Court: 9, 19th Floor
Judge: Hon. James Ware

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STIPULATION AND [PROP.] ORDER EXTENDING
DEADLINES FOR RESPONSE AND REPLY BRIEFS
CASE NO. 3:11-CV-05403-JW

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WHEREAS, pursuant to the Court’s February 7, 2012 Order, the parties submitted a Joint

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Statement on March 2, 2012, to discuss the impact of Mazza v. American Honda Co., 666 F.3d

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581 (9th Cir. 2012) on this case and submitted a stipulated schedule for the Court’s approval

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(Doc. No. 43);

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WHEREAS the Court indicated in its subsequent Scheduling Order that the hearing for

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NVIDIA Corporation’s (“NVIDIA”) Motion to Dismiss Plaintiff’s Second Amended Class

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Action Complaint would be set for June 11, 2012, and that the “Motion shall be noticed and

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briefed in accordance with the Civil Local Rules” (Doc. No. 44);

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WHEREAS the Commentary to Civil Local Rule 7-2 provides: “The time periods set forth

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in Civil L.R. 7-2 and 7-3 regarding notice, response and reply to motions are minimum time

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periods. For complex motions, parties are encouraged to stipulate to or seek a Court order

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establishing a longer notice period with correspondingly longer periods for response or reply”;

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WHEREAS the parties believe the pending Motion to Dismiss is sufficiently complex to

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justify an extension of the periods allowed under the Civil Local Rules for the filing of the

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parties’ opposition and reply briefs, and the parties believe that it would be difficult to prepare the

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opposition and reply briefs within the minimum time allotments provided by Civil Local Rule 7-

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3;

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WHEREAS the proposed extension of the briefing deadlines would not affect any other
deadlines in the case schedule or the scheduled hearing date1;

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Accordingly, IT IS HEREBY STIPULATED AND AGREED, by Plaintiff and Defendant,

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through their counsel of record, that Plaintiff’s deadline for filing its response to NVIDIA’s

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Motion to Dismiss shall be extended to May 11, 2012, and that NVIDIA’s deadline for filing its

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reply in support of its Motion shall be extended to May 25, 2012.

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Pursuant to Civil Local Rule 6-2, the parties are filing the accompanying declaration of Jason A.
Pikler in support of the Stipulation.
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STIPULATION AND [PROP.] ORDER EXTENDING
DEADLINES FOR RESPONSE AND REPLY BRIEFS
CASE NO. 3:11-CV-05403-JW

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Dated: April 18, 2012

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ORRICK, HERRINGTON & SUTCLIFFE LLP
By: /s/ Robert P. Varian
Robert P. Varian, Bar No. 107459
[e-mail]
The Orrick Building
405 Howard Street
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant
NVIDIA Corporation

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Dated: April 18, 2012

SHAPIRO HABER & URMY LLP
By: /s/ Edward F. Haber
Edward F. Haber (pro hac vice)
[e-mail]
53 State Street
Boston, MA 02109
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff and the
Putative Class

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
S

ERED

O ORD

IT IS S

THE HONORABLE JAMES WAREre
a
UNITED STATES DISTRICT mes W
Judge Ja COURT JUDGE
NO

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4/24/12
DATED: _______________________

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I, Jason Pikler, am the ECF user whose ID and password are being used to file this Stipulation
and [Proposed] Order Extending Deadlines for Response and Reply Briefs Regarding Nvidia’s
Motion to Dismiss. In compliance with General Order 45, X.B., I hereby attest that Edward
Haber and Robert Varian have concurred in this filing.

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STIPULATION AND [PROP.] ORDER EXTENDING
DEADLINES FOR RESPONSE AND REPLY BRIEFS
CASE NO. 3:11-CV-05403-JW