Circle Click Media LLC v. Regus Management Group LLC et al

Filing 186

STIPULATION AND ORDER Enlarging Time to Respond and Reply. Set/Reset Deadlines as to #180 MOTION to Dismiss. Responses due by 7/18/2014. Replies due by 7/28/2014. Signed by Judge Samuel Conti on 07/03/2014. (tmi, COURT STAFF) (Filed on 7/3/2014)

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GAROFOLO LAW GROUP, P.C.
Joseph A. Garofolo, California Bar No. 214614
E-mail: [e-mail]
90 New Montgomery Street, Suite 905
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]

ARI LAW, P.C.
Ali Aalaei, California Bar No. 254713
E-mail: [e-mail]
90 New Montgomery Street, Suite 905
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]

Attorneys for Plaintiffs
CIRCLE CLICK MEDIA LLC and CTNY
INSURANCE GROUP LLC

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BRYAN CAVE LLP
K. Lee Marshall, California Bar No. 277092
Meryl Macklin, California Bar No. 115053
Daniel Thomas Rockey, California Bar No. 178604
Stephanie Blazewicz, California Bar No. 240359
Bahareh Wullschleger, California Bar No. 258903
560 Mission Street, 25th Floor
San Francisco, CA 94105
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Christopher J. Schmidt (pro hac vice)
211 N. Broadway, Suite 3600
St. Louis, MO 63102
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]

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Attorneys for Defendants
REGUS MANAGEMENT GROUP, LLC, REGUS
BUSINESS CENTRE, LLC, REGUS plc, and HQ
GLOBAL WORKPLACES LLC

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STIPULATION AND [PROPOSED] ORDER
CASE NO. 3:12-CV-04000 SC (JSC)

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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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CIRCLE CLICK MEDIA LLC, et al.,

Case No. 3:12-CV-04000 SC (JSC)

Plaintiffs,

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STIPULATION AND [PROPOSED]
ORDER TO ENLARGE TIME FOR
PLAINTIFFS TO FILE THEIR
OPPOSITION TO DEFENDANT’S
RENEWED MOTION TO DISMISS
REGUS PLC FOR LACK OF PERSONAL
JURISDICTION AND FOR DEFENDANT
REGUS PLC TO FILE ITS REPLY
THERETO

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vs.
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REGUS MANAGEMENT GROUP, LLC,
et al.,

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Defendants.

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STIPULATION

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Pursuant to Civil L.R. 6-2 and 7-12, Plaintiffs Circle Click Media LLC and CTNY

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Insurance Group LLC (collectively, “Plaintiffs”) and Defendants Regus Management Group, LLC,

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Regus Business Centre, LLC, Regus plc, and HQ Global Workplaces LLC (collectively,

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“Defendants”) hereby stipulate and request that the time for Plaintiffs to file their opposition to

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Defendant’s Renewed Motion to Dismiss Regus plc for Lack of Personal Jurisdiction (“Motion”)

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(Doc. 180) be enlarged from July 9, 2014, until, and including, July 18, 2014, and that the time for

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Defendant to reply be enlarged from seven calendar days to ten calendar days such that Defendant

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Regus plc’s reply would be due by, and including, July 28, 2014.

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This is a putative class action brought on behalf of California and New York classes

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alleging, inter alia, unfair business practices. (See Joint Case Management Statement (Doc. 116)

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at 1-2). On June 25, 2014, Defendant Regus plc filed its Motion along with three declarations and

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evidentiary submissions. (Declaration of Joseph A. Garofolo ¶ 3 filed concurrently herewith).

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Plaintiffs request a nine-day enlargement due to pretrial preparation anticipated in another federal

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case pending in this jurisdiction currently set for trial in August of 2014, wherein Plaintiffs’ lead

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counsel also serves as lead counsel in that case. (Id. at ¶ 4). Defendant requests a modest
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Case No. 3:12-CV-04000 SC (JSC)

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enlargement of the time to file its reply from seven days to ten days so that counsel has sufficient

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time to review and reply to Plaintiffs’ opposition. (See id. at ¶ 5).

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This is the first request for an enlargement of the time for Plaintiffs to file an opposition to

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Defendant’s Motion and the first request for an enlargement of time for Defendant to file a reply.

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(Id. at ¶ 6).

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The parties do not believe that the requested enlargement will have any effect on the

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overall schedule for this case as the hearing on Defendant’s Motion is calendared for September 5,

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2014. (See Clerk’s Notice Clarifying Briefing Schedule (Doc. 182); id. at ¶ 7).

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IT IS SO STIPULATED.
Dated: July 1, 2014

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GAROFOLO LAW GROUP, P.C.
By: /s/ Joseph A. Garofolo
Joseph A. Garofolo
Attorneys for Plaintiffs
CIRCLE CLICK MEDIA LLC and CTNY
INSURANCE GROUP LLC

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BRYAN CAVE LLP

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By: /s/ K. Lee Marshall
K. Lee Marshall
Attorneys for Defendants
REGUS MANAGEMENT GROUP, LLC, REGUS
BUSINESS CENTRE, LLC, REGUS plc, and HQ
GLOBAL WORKPLACES LLC

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ORDER
Pursuant to the Stipulation, and good cause appearing, the Court orders that Plaintiffs may
file their opposition to Defendant’s Renewed Motion to Dismiss Regus plc for Lack of Personal

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Jurisdiction by, and including, July 18, 2014, and Defendant may file its reply by, and including,

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July 28, 2014.

R NIA

onti

FO

amuel C

Judge S

RT

ER

LI

UNITED STATES DISTRICT JUDGE
H

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NO

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03
Dated: July ___, 2014

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IT IS SO ORDERED.

UNIT
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Case No. 3:12-CV-04000 SC (JSC)

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