Yordy v. Plimus, Inc et al

Filing 31

STIPULATION AND ORDER Extending Briefing Schedule Relating to Defendants' Motion to Dismiss Complaint. Responses due by 3/23/2012. Replies due by 4/6/2012. Signed by Judge Thelton E. Henderson on 03/16/2012. (tmi, COURT STAFF) (Filed on 3/16/2012)

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Sean P. Reis (SBN 184004)
[e-mail]
EDELSON MCGUIRE LLP
30021 Tomas Street, Suite 300
Rancho Santa Margarita, California 92688
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff Kimberly Yordy

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Nickolas A. Kacprowski (SBN 242684)
[e-mail]
KIRKLAND & ELLIS LLP
555 California Street
San Francisco, California 94104
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendants Plimus, Inc. and Great Hill Partners, LLC

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[Additional counsel included in signature block.]

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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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KIMBERLY YORDY, on behalf of herself and all
others similarly situated,
Plaintiff,

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v.
PLIMUS, INC., a California corporation, and
GREAT HILL PARTNERS, LLC, a Massachusetts
limited liability company,

Case No. 12-cv-00229-TEH
STIPULATION FOR EXTENSION OF
BRIEFING SCHEDULE RELATED TO
DEFENDANTS’ MOTION TO DISMISS
COMPLAINT
Judge: Honorable Thelton E. Henderson
Action filed: January 13, 2012

Defendants.

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STIPULATION EXTENDING
BRIEFING SCHEDULE

CASE NO. 12-CV-00229-TEH

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Pursuant to Local Rule 7-12 and this Court’s Standing Order, Plaintiff Kimberly Yordy and

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Defendants Plimus, Inc. (“Plimus”) and Great Hill Partners, LLC (“Great Hill”) (collectively, the

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“Parties”), by and through their undersigned counsel, hereby stipulate and agree to extend the

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briefing schedule on Defendants’ pending motion to dismiss Plaintiff’s Complaint. In support of the

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instant stipulation, the Parties state as follows:

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WHEREAS, on January 13, 2012, Plaintiff Yordy filed her putative class action complaint
(the “Complaint”) against Plimus and Great Hill, (Dkt. No. 1);
WHEREAS, on March 2, 2012, Plimus and Great Hill jointly moved to dismiss the
Complaint in its entirety, (Dkt. No. 29);
WHEREAS, Plaintiff is currently reviewing the arguments made in Defendants’ pending
motion;
WHEREAS, Plaintiff requires additional time to prepare an adequate response to
Defendants’ motion;
WHEREAS, the Parties have conferred regarding Plaintiff’s need for additional time to

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prepare a response to Defendants’ motion, and have agreed that she may have an extension of time

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through and including March 23, 2012, to file her opposition to the motion;

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WHEREAS, the Parties have further agreed that following the filing of Plaintiff’s

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opposition, Defendants shall have through and including April 6, 2012, to reply in support of their

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motion;

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WHEREAS, good cause exists for the extensions of time contemplated herein and such
extensions are not sought for any improper purpose;

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NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED:

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1.

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Plaintiff shall have an extension of time through and including March 23, 2012, to

file her response to Defendants’ pending motion to dismiss the Complaint;
2.

Defendants shall have through and including April 6, 2012, to file a reply in support

of their motion to dismiss the Complaint; and,

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STIPULATION EXTENDING
BRIEFING SCHEDULE

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CASE NO. 12-CV-00229-TEH

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3.

All other briefing deadlines with respect to Defendants’ pending motion to dismiss

the Complaint are hereby vacated.
IT IS SO STIPULATED.

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KIMBERLY YORDY, on behalf of herself and all
others similarly situated,

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Dated: March 15, 2012

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Sean P. Reis (SBN 184004)
[e-mail]
EDELSON MCGUIRE LLP
30021 Tomas Street, Suite 300
Rancho Santa Margarita, California 92688
Telephone: [phone]
Facsimile: [phone]

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Rafey S. Balabanian (Admitted Pro Hac Vice)
[e-mail]
Christopher L. Dore (Admitted Pro Hac Vice)
[e-mail]
Benjamin H. Richman (Admitted Pro Hac Vice)
[e-mail]
EDELSON MCGUIRE LLC
350 North LaSalle Street, Suite 1300
Chicago, Illinois 60654
Telephone: [phone]
Facsimile: [phone]

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PLIMUS, INC. and GREAT HILL
PARTNERS, LLC,

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By: /s/ Sean P. Reis
One of Plaintiff’s Attorneys

Dated: March 15, 2012

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By: /s/ Jordan M. Heinz
One of Defendants’ Attorneys
Nickolas A. Kacprowski (SBN 242684)
[e-mail]
KIRKLAND & ELLIS LLP
555 California Street
San Francisco, California 94104
Telephone: [phone]
Facsimile: [phone]

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STIPULATION EXTENDING
BRIEFING SCHEDULE

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CASE NO. 12-CV-00229-TEH

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Jeffrey L. Willian (Admitted Pro Hac Vice)
[e-mail]
Jordan M. Heinz (Admitted Pro Hac Vice)
[e-mail]
Sylvia Nichole Winston (Admitted Pro Hac Vice)
[e-mail]
KIRKLAND & ELLIS LLP
300 North LaSalle Street
Chicago, Illinois 60654
Telephone: [phone]
Facsimile: [phone]

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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03/16/2012

UNIT
ED

DATED:

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HONORABLE THELTON E. HENDERSON
UNITED STATES DISTRICT JUDGE

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STIPULATION EXTENDING
BRIEFING SCHEDULE

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CASE NO. 12-CV-00229-TEH