Raney v. Twitter, Inc.
Filing
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STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO FIRST AMENDED CLASS ACTION COMPLAINT AND SET BRIEFING SCHEDULE FOR MOTION TO STAY by Hon. William Alsup granting 26 Stipulation.(whalc1, COURT STAFF) (Filed on 10/13/2015)
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COOLEY LLP
MICHAEL G. RHODES (116127) (rhodesmg@cooley.com)
WHITTY SOMVICHIAN (194463) (wsomvichian@cooley.com)
KYLE C. WONG (224021) (kwong@cooley.com)
DEVON HANLEY COOK (262626) (dhanleycook@cooley.com)
101 California Street, 5th Floor
San Francisco, CA 94111-5800
Telephone:
(415) 693-2000
Facsimile:
(415) 693-2222
Attorneys for Defendant
TWITTER, 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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WILFORD RANEY, as an individual, and on
behalf of the others similarly situated,
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Plaintiff,
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v.
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TWITTER, INC., a Delaware corporation,
Case No. 3:15-cv-04191-WHA
STIPULATION AND [PROPOSED] ORDER
TO EXTEND TIME TO RESPOND TO
FIRST AMENDED CLASS ACTION
COMPLAINT AND SET BRIEFING
SCHEDULE FOR MOTION TO STAY (CIVIL
L.R. 6-1(A), (B); 6-2)
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Defendant.
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Judge:
Date:
Hon. William H. Alsup
Not yet set
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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO
122358093
STIPULATION TO EXTEND TIME TO RESPOND TO
INITIAL COMPLAINT
3:15-CV-04191-WHA
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Pursuant to Civil Local Rules 6-1(a), 6-1(b), and 6-2, plaintiff Wilford Raney (“Plaintiff”)
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and defendant Twitter, Inc. (“Twitter”) (collectively “the Parties”), by and through their
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respective counsel, stipulate and agree as follows:
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WHEREAS, Plaintiff filed a putative class action lawsuit against Twitter on or about
September 14, 2015;
WHERAS, Plaintiff filed his First Amended Class Action Complaint (“FAC”) on
September 30, 2015;
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WHEREAS, Twitter’s deadline to respond to the Complaint is October 19, 2015;
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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, under Civil Local Rule 6-1(b), a Court order is required for any enlargement
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of time that alters a deadline that involves papers required to be filed with the Court (other than
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an initial response to the complaint);
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WHEREAS, the parties may file a stipulation requesting an order that would extend time
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frames set in the Federal Rules, accompanied by a declaration complying with Civil Local Rule
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6-2, and such a declaration is filed herewith;
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WHEREAS, the Parties have agreed to stipulate under Civil Local Rule 6-1(a) and (b) to a
filing and briefing schedule for Twitter’s response to the FAC as set forth below;
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WHEREAS, the Parties have stipulated under Civil Local Rule 6-1(b) to a filing and
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briefing schedule for Twitter’s anticipated motion to stay this action (“Motion to Stay”) as set
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forth below;
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WHEREAS, extending the deadline for any subsequent briefing necessitated by Twitter’s
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response to the Complaint and Motion to Stay, as set forth below, will allow for a more complete
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and orderly presentation of the complex legal issues the Court will need to resolve in both
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motions (see Declaration of Whitty Somvichian (“Somvichian Decl.”) ¶ 3, filed concurrently
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herewith);
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WHEREAS, extending the deadlines for any subsequent briefing necessitated by Twitter’s
COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO
122358093
1.
STIPULATION TO EXTEND TIME TO RESPOND TO
INITIAL COMPLAINT
3:15-CV-04191-WHA
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response to the Complaint or Motion to Stay will help accommodate attorneys’ schedules
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for the upcoming holidays.
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WHEREAS, no prior time modifications have been sought in this case (id. ¶ 6);
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WHEREAS, this modification would not affect the case schedule as none has been
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entered (id. ¶ 7).
NOW THEREFORE, the Parties hereby stipulate and agree to extend the following
deadlines:
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1. November 9, 2015:
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Twitter’s deadline to respond to the FAC and file its
anticipated Motion to Stay;
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2. December 9, 2015:
Plaintiff’s Oppositions due;
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3. January 9, 2015:
Twitter’s Replies due.
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IT IS SO STIPULATED.
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Dated: October 8, 2015
COOLEY LLP
s/ Whitty Somvichian
Whitty Somvichian (194463)
Attorneys for Defendant Twitter, Inc.
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Dated: October 8, 2015
s/ Alexander T.H. Nguyen
Alexander T.H. Nguyen
Attorneys for Plaintiff
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EDELSON PC
Filer’s Attestation: Pursuant to Civil Local Rule 5-1(i)(3)) 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.
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DATED: October 13, 2015.
The Honorable William H. Alsup
United States District Judge
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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO
122358093
2.
STIPULATION TO EXTEND TIME TO RESPOND TO
INITIAL COMPLAINT
3:15-CV-04191-WHA
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