Castillo et al v. Seagate Technology, LLC

Filing 47

STIPULATION AND ORDER 46 Continuing Plaintiffs' Time to File Amended Complaint. Signed by Judge Richard Seeborg on 10/3/16. (cl, COURT STAFF) (Filed on 10/3/2016)

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DAVID F. MCDOWELL (CA SBN 125806)
[e-mail]
MORRISON & FOERSTER LLP
707 Wilshire Boulevard
Los Angeles, California 90017-3543
Telephone: [phone]
Facsimile: 213.892.5454
TIFFANY CHEUNG (CA SBN 211497)
[e-mail]
ALEXANDRA E. LAKS (CA SBN 291861)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: 415.268.7522
Attorneys for Defendant
SEAGATE TECHNOLOGY LLC

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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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EVERETT CASTILLO, LINDA CASTILLO,
NICHOLAS DATTOMA, FREDA LANG,
WENDY TRAN, and STEVEN WILK,
individually and on behalf of all others similarly
situated,

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3:16-cv-01958-RS

STIPULATION AND [PROPOSED]
ORDER CONTINUING
PLAINTIFFS’ TIME TO FILE
AMENDED COMPLAINT

Plaintiffs,

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Case No.

v.

Judge:
Action Filed:

Hon. Richard Seeborg
April 14, 2016

SEAGATE TECHNOLOGY LLC,
Defendant.

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STIPULATION AND [PROPOSED] ORDER CONTINUING PLAINTIFF’S TIME TO FILE AMENDED COMPLAINT
CASE NO. 3:16-CV-01958-RS
336469.1 SEAGATE

Pursuant to Local Rules 6-2 and 7-12, Plaintiffs EVERETT CASTILLO, LINDA

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CASTILLO, NICHOLAS DATTOMA, FREDA LANG, WENDY TRAN, and, STEVEN

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WILK (“Plaintiffs”), on behalf of themselves and all others similarly situated, and Defendant

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Seagate Technology LLC (“Seagate”), through their undersigned counsel, hereby stipulate as

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follows:
WHEREAS, on June 15, 2016, the Court granted the parties’ stipulation to consolidate

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the following two actions : Castillo et al. v. Seagate Technology LLC, No. 3:16-cv-01958-RS

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(filed on April 14, 2016) and Dattoma v. Seagate Technology LLC, No. C5:16-cv-02136-RS

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(filed on April 21, 2016) (Dkt. No. 19);
WHEREAS, Plaintiffs filed their Consolidated Class Action Complaint on June 28, 2016

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(Dkt. No. 22);
WHEREAS, Seagate moved to dismiss the Consolidated Class Action Complaint on

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July 28, 2016 (Dkt. No. 29);
WHEREAS, by order entered September 14, 2016 (Dkt. No. 39), the Court granted in

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part and denied in part Seagate’s motion to dismiss, and the Court granted Plaintiff leave to

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amend their complaint within 20 days of the order;
WHEREAS, Plaintiffs’ deadline to amend the complaint is currently October 4, 2016,

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which is the second day of the Rosh Hashana holiday;
WHEREAS, on September 29, 2016, counsel for the parties discussed issues related to

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Plaintiffs’ anticipated amended complaint and certain information Plaintiff intends to allege that

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may need to be filed under seal;
WHEREAS, the parties intend to continue their discussions to determine whether

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information contained in the anticipated amended complaint should be filed under seal;
WHEREAS, the parties have previously requested an order continuing a case

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management conference, which was granted on July 6, 2016 (Dkt. No. 28), and a fourteen-day

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extension of time to respond to the Complaint filed on April 14, 2016, pursuant to Local Rule 6-

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STIPULATION AND [PROPOSED] ORDER CONTINUING PLAINTIFF’S TIME TO FILE AMENDED COMPLAINT
CASE NO. 3:16-CV-01958-RS
336469.1 SEAGATE

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WHEREAS, in light of the intervening holiday and in order to efficiently attempt to

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resolve any issues concerning confidentiality, plaintiffs have requested, and defendant does not

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oppose, an extension of plaintiffs’ deadline to file their amended complaint by fourteen (14)

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days, through and including October 18, 2016.

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IT IS HEREBY STIPULATED AND AGREED by the parties, through their counsel,

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subject to the approval of the Court, that the October 4, 2016, deadline for plaintiffs’ to file their

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amended complaint is continued through and including October 18, 2016.

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Dated: September 30, 2016

GLANCY PRONGAY & MURRAY LLP
By: /s/ Marc S. Greenstone
Lionel Z. Glancy
Marc L. Godino
Mark S. Greenstone
1925 Century Park East, Suite 2100
Los Angeles, CA 90067
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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BRAGAR EAGEL & SQUIRE, P.C.
David J. Stone (Pro Hac Vice)
Jeffrey H. Squire (Pro Hac Vice)
Lawrence P. Eagel (Pro Hac Vice)
885 Third Avenue, Suite 3040
New York, NY 10022
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]

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Attorneys for Plaintiffs
EVERETT CASTILLO, LINDA CASTILLO,
WENDY TRAN, AND THE CLASS

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KELLER GROVER LLP
Eric A. Grover
1965 Market Street
San Francisco, CA 94103
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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STIPULATION AND [PROPOSED] ORDER CONTINUING PLAINTIFF’S TIME TO FILE AMENDED COMPLAINT
CASE NO. 3:16-CV-01958-RS
336469.1 SEAGATE

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FINKELSTEIN, BLANKINSHIP, FREIPEARSON & GARBER, LLP
Jeremiah Frei-Pearson (Pro Hac Vice)
445 Hamilton Avenue, Suite 605
White Plains, NY 10601
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Plaintiffs
NICHOLAS DATTOMA, FREDA LANG,
STEVEN WILK, AND THE CLASS

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By: /s/ Tiffany Cheung
David F. McDowell
Tiffany Cheung
Alexandra E. Laks
425 Market Street
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]

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Attorneys for Defendant
SEAGATE TECHNOLOGY LLC

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PURSUANT TO STIPULATION, IT IS SO ORDERED

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Dated: 10/3/16

__________________________________
The Honorable Richard Seeborg

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STIPULATION AND [PROPOSED] ORDER CONTINUING PLAINTIFF’S TIME TO FILE AMENDED COMPLAINT
CASE NO. 3:16-CV-01958-RS
336469.1 SEAGATE

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