Keirsey v. eBay, Inc

Filing 20

ORDER GRANTING AS MODIFIED #19 STIPULATION TO EXTEND TIME TO RESPOND TO INITIAL COMPLAINT (CIVIL L.R. 6-1(A)); STIPULATED REQUEST TO CHANGE DATE OF INITIAL CASE MANAGEMENT CONFERENCE (CIVIL L.R. 6-2). Case Management Statement due by 6/29/2012. Initial Case Management Conference set for 7/6/2012 01:30 PM in Courtroom 11, 19th Floor, San Francisco.. Signed by Judge Jeffrey S. White on 4/9/12. (jjoS, COURT STAFF) (Filed on 4/9/2012)

Case3:12-cv-01200-JSW Document19 Filed04/06/12 Page1 of 3

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COOLEY LLP
JOHN C. DWYER (136533)
([e-mail])
Five Palo Alto Square
3000 El Camino Real
Palo Alto, CA 94306-2155
Telephone:
[phone]
Facsimile:
[phone]
COOLEY LLP
MICHAEL G. RHODES (116127)
([e-mail])
WHITTY SOMVICHIAN (194463)
([e-mail])
RAY SARDO (245421)
([e-mail])
101 California Street, 5th Floor
San Francisco, CA 94111-5800
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendants eBay Inc.

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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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TASHA KEIRSEY, Individually and on
behalf of all others similarly situated,
Plaintiff,
v.
EBAY, INC.,
Defendant.

Case No. CV12-01200 JSW
STIPULATION AND [PROPOSED]
ORDERTO EXTEND TIME TO RESPOND
TO INITIAL COMPLAINT (CIVIL L.R. 61(A)); STIPULATED REQUEST TO
CHANGE DATE OF INITIAL CASE
MANAGEMENT CONFERENCE (CIVIL
L.R. 6-2)
Judge:
Hon. Jeffrey S. White
Trial Date: Not yet set

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COOLEY LLP
ATTORNEYS AT LAW
SAN DIEGO

STIPULATION TO MOVE CMC AND EXTEND
TIME TO RESPOND TO INITIAL COMPLAINT
(CIVIL L.R. 6-1(A)); CV12-01200 JSW
C
N . CV12-01200 JSW

Case3:12-cv-01200-JSW Document19 Filed04/06/12 Page2 of 3

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Pursuant to Civil Local Rules 6-1(a) and 6-2, plaintiff Tasha Keirsey (“Plaintiff”) and

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defendant eBay Inc. (“Defendant”) (Plaintiff and Defendant collectively “the Parties”), by and

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through their respective counsel, stipulate and agree as follows:

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WHEREAS, Plaintiff filed a putative class action lawsuit against Defendant on or about
March 9, 2012;

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WHEREAS, under Civil Local Rule 6-1(a), the Parties may stipulate in writing, without a

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Court order, to extend the time within which to answer or otherwise respond to the complaint,

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provided the change will not alter any deadline already fixed by Court order;

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WHEREAS the Parties have stipulated under Civil Local Rule 6-1(a) to a filing and

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briefing schedule for eBay’s response to the Complaint as set forth below, with a proposed

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hearing date of June 26, 2012;

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WHEREAS, the Initial Case Management Conference in this matter is currently set for
June 8, 2012 (Dkt. No. 17);

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WHEREAS, under Civil Local Rule 6-2 and this Court’s Case Management Conference

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Order (Dkt. No. 17), the Parties may file a stipulation requesting an order changing the date of the

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Initial Case Management Conference;

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WHEREAS, the Parties have conferred and agreed to request that the Initial Case

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Management Conference currently scheduled for June 8, 2012 be rescheduled to the same date as

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the proposed date for the hearing on Defendant’s anticipated motion to dismiss the Complaint

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(June 26, 2012);

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WHEREAS, no prior time modifications affecting the Initial Case Management
Conference have occurred in this case.
NOW THEREFORE, the Parties hereby stipulate and agree to extend the following
deadlines:

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1. May 7, 2012:

Defendant’s deadline to respond to the Complaint;

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2. May 29, 2012:

Plaintiff’s Opposition due;

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3. June 12, 2012
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4. June 26, 2012

Defendant’s Reply due;

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COOLEY LLP
ATTORNEYS AT LAW
SAN DIEGO

Hearing date, subject to the Court’s approval.
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STIPULATION TO MOVE CMC AND EXTEND
TIME TO RESPOND TO INITIAL COMPLAINT
(CIVIL L.R. 6-1(A)); CV12-01200 JSW
C
N . CV12-01200 JSW

Case3:12-cv-01200-JSW Document19 Filed04/06/12 Page3 of 3

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FURTHER, the Parties hereby stipulate and request that the Initial Case Management
July 6, 2012
Conference be rescheduled to June 26, 2012 to coincide with the requested hearing date set forth

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above.

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IT IS SO STIPULATED.

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Dated: April 6, 2012

COOLEY LLP
___________________________________
/s/Whitty Somvichian
Whitty Somvichian (194463)
Attorneys for Defendants eBay Inc.

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Dated: April 6, 2012

FIGARI & DAVENPORT, L.L.P.
____________________________________
/s/Keith R. Verges
Keith R. Verges (pro hac vice)
Attorneys for Plaintiff

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Filer’s Attestation: Pursuant to General Order No. 45, Section X(B) regarding signatures, Whitty
Somvichian hereby attests that concurrence in the filing of this document has been obtained.

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PROPOSED ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED. AS MODIFIED, IT IS SO ORDERED.

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DATED:

April 9, 2012
__________

___________________________
The Honorable Jeffrey S. White
United States District Judge

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1263196 v1/SF

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COOLEY LLP
ATTORNEYS AT LAW
SAN DIEGO

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STIPULATION TO MOVE CMC AND EXTEND
TIME TO RESPOND TO INITIAL COMPLAINT
(CIVIL L.R. 6-1(A)); CV12-01200 JSW
C
N . CV12-01200 JSW