Facebook Inc. v. Tarquini

Filing 46

STIPULATION WITH PROPOSED ORDER re 38 Case Management Scheduling Order, Set Hearings,,,, filed by Facebook Inc.. (Gerlicher, Amelia) (Filed on 8/18/2014)

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Brian Hennessy, State Bar No. 226721
[e-mail]
PERKINS COIE LLP
3150 Porter Drive
Palo Alto, CA 94304-1212
Telephone: [phone]
Facsimile: 650.838.4350
Amelia Gerlicher, pro hac vice
[e-mail]
PERKINS COIE LLP
2901 North Central Avenue, Suite 2000
Phoenix, Arizona 85012-2788
Attorneys for Plaintiff
FACEBOOK, INC.

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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Case No. CV 13-05312 VC / DMR

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FACEBOOK, INC., a Delaware
corporation,

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Plaintiff,

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v.
CHRISTOPHER PETER TARQUINI, an
individual,
Defendant.

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STIPULATION REGARDING
DISCOVERY CUTOFF

Plaintiff Facebook, Inc. (“Facebook”) and Defendant Christopher Tarquini hereby stipulate
and agree as follow:

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WHEREAS, the discovery cutoff is currently September 2, 2014.

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WHEREAS, on June 10, 2014, Facebook served Mr. Tarquini with its First Set of Requests

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for Production and First Set of Interrogatories.
WHEREAS, on July 29, 2013, Facebook served Mr. Tarquini with its First Set of Requests
for Admission and Second Set of Interrogatories.

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P ERKINS C OIE LLP

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ATTO RNEY S AT LAW
PALO AL TO

LEGAL123071909.1

STIPULATION AND [PROPOSED] ORDER
e No. CV 13-05312 VC

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WHEREAS, on August 6, 2014, Mr. Tarquini’s counsel, John Zohlman, withdrew. Since

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then, counsel for Facebook has been communicating directly with Mr. Tarquini to resolve the

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parties’ discovery issues.

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WHEREAS, on August 13, 2014, Mr. Tarquini produced his first set of documents

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responsive to Facebook’s Requests for Production and committed to providing additional

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documents by August 15, 2014.

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WHEREAS, Facebook intends to depose Mr. Tarquini after he has finished responding to
Facebook’s discovery requests.
WHEREAS, the parties have agreed to a modest extension in order to allow Mr. Tarquini to

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finish responding to the outstanding discovery requests and to allow Facebook adequate time to

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review his responses and depose Mr. Tarquini.

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IT IS HEREBY STIPULATED AND AGREED that the discovery cutoff will be extended

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to October 2, 2014. This stipulation does not affect the other existing case deadlines set by the

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Court in its Case Management Scheduling Order. See Dkt. No. 38

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DATED: August 18, 2014

PERKINS COIE LLP

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By: /s/ Amelia Gerlicher
Amelia Gerlicher

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Attorney for Plaintiff Facebook, Inc.

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DATED: August 18, 2014

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By: /s/ Christopher Tarquini
Christopher Tarquini

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Defendant

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Pursuant to Local Rule 5-1(i), the filer attests that the concurrence in the filing of this
document has been obtained from each of the above signatories.

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P ERKINS C OIE LLP

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ATTO RNEY S AT LAW
PALO AL TO

LEGAL123071909.1

STIPULATION AND [PROPOSED] ORDER
e No. CV 13-05312 VC

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Brian Hennessy, State Bar No. 226721
[e-mail]
PERKINS COIE LLP
3150 Porter Drive
Palo Alto, CA 94304-1212
Telephone: [phone]
Facsimile: 650.838.4350
Amelia Gerlicher, pro hac vice
[e-mail]
PERKINS COIE LLP
2901 North Central Avenue, Suite 2000
Phoenix, Arizona 85012-2788
Attorneys for Plaintiff
FACEBOOK, INC.

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UNITED STATES DISTRICT COURT
11
NORTHERN DISTRICT OF CALIFORNIA
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Case No. CV 13-05312 VC/DMR

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FACEBOOK, INC., a Delaware
corporation,

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Plaintiff,

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v.
CHRISTOPHER PETER TARQUINI, an
individual,
Defendant.

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[PROPOSED] ORDER REGARDING
DISCOVERY CUTOFF

The Court, having considered the stipulation of the parties, and good cause appearing,

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orders that the discovery cutoff be extended to October 2, 2014. This order does not affect the other

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existing case deadlines set by the Court in its Case Management Scheduling Order.

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See Dkt. No. 38.

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IT IS SO ORDERED.

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DATED:

__________

Hon. Vince Chahabria
United States District Judge

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P ERKINS C OIE LLP

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ATTO RNEY S AT LAW
PALO AL TO

LEGAL123071909.1

STIPULATION AND [PROPOSED] ORDER
e No. CV 13-05312 VC