Meta Company v. Zhong et al

Filing 47

STIPULATION AND ORDER re 46 to Extend Deadlines re Motion to Expedite Discovery and Motion to Dismiss filed by Meta Company. Motion Hearing for Expedited Discovery reset for 8/24/2017 01:30 PM in Courtroom 5, 17th Floor, San Franc isco before Edward M. Chen. Motion to Dismiss Hearing sreet for 8/31/2017 01:30 PM in Courtroom 5, 17th Floor, San Francisco before Edward M. Chen. Opposition due: 8/10/17. Reply due 8/17/17. Signed by Judge Edward M. Chen on 7/19/17. (bpfS, COURT STAFF) (Filed on 7/20/2017)

1 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
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A Limited Liability Partnership
Including Professional Corporations
JENNIFER G. REDMOND, Cal. Bar No. 144790
[e-mail]
PAUL S. COWIE, Cal. Bar No. 250131
[e-mail]
JOHN-PAUL S. DEOL, Cal. Bar No. 284893
[e-mail]
Four Embarcadero Center, 17th Floor
San Francisco, CA 94111-4109
Telephone:
415.434.9100
Facsimile:
415.434.3947

9 Attorneys for Plaintiff
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META COMPANY

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

14 META COMPANY, a Delaware corporation,

Case No. 3:17-cv-03259-EMC

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STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINES RE
MOTION FOR EXPEDITED DISCOVERY
AND MOTION TO DISMISS

Plaintiff,

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v.
ZHANGYI ZHONG (a.k.a. Zhangyi “Johnny”

18 Zhong, a.k.a. Zhangyi “Kevin” Zhong), an
individual, DREAMWORLD USA INC., a

19 Delaware corporation, and DOES 1 through
20 20.
Defendants.

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Case No. 3:17-cv-03259-EMC
SMRH:483499192.2

STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES RE MOTION FOR
EXPEDITED DISCOVERY AND MOTION TO DISMISS

Pursuant to Local Rule 6-2 of the Northern District of California, Defendants Zhangyi Zhong

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2 and Dreamworld USA Inc. (“Defendants”) and Plaintiff Meta Company (“Meta” or “Plaintiff”)
3 hereby stipulate to move the hearing dates and extend the briefing deadlines on Plaintiff’s Motion
4 for Expedited Discovery (“Expedited Discovery Motion”) (Dkt. No. 21) and Defendant’s Motion to
5 Dismiss (“Motion to Dismiss”) (Dkt. No. 38).
WHEREAS, the Parties are currently attempting to informally resolve the above-captioned

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7 lawsuit (Deol Decl., ¶ 2);
WHEREAS, the Parties wish to avoid spending additional time and effort in briefing and

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9 attending a hearing on the Expedited Discovery Motion and Motion to Dismiss in the event this case
10 can be informally resolved (Deol Decl., ¶ 3);
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WHEREAS the Expedited Discovery Motion is set for hearing on August 3, 2017;

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WHEREAS the Motion to Dismiss is set for hearing on August 17, 2017;

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WHEREAS, Plaintiff’s opposition to the Motion to Dismiss is currently due on July 21,

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WHEREAS, Defendants’ reply in support of the Motion to Dismiss is currently due on July

16 28, 2017;
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WHEREAS, there have been no previous time modifications in this case, with the exception

18 of a short extension of time for Defendants to file a response to the Complaint (Deol Decl., ¶ 4);
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WHEREAS, counsel for both Parties agree that the requested extension would not affect any

20 other deadlines in this case (Deol Decl., ¶ 5); and
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WHEREAS, Civil Local Rule 6-2(a) of the Northern District of California states, “The

22 parties may file a stipulation … requesting an order changing time that would affect the date of an
23 event or deadline already fixed by Court order, or that would accelerate or extend time frames set
24 in the Local Rules or in the Federal Rules.”
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NOW, THEREFORE, in consideration of the foregoing, the Parties agree and hereby

26 stipulate that:
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(1)

the hearing on the Expedited Discovery Motion be continued to August 24, 2017;

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-1SMRH:483499192.2

Case No. 3:17-cv-03259-EMC

STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES RE MOTION FOR
EXPEDITED DISCOVERY AND MOTION TO DISMISS

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(2)

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(3)

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Plaintiff may file its opposition to the Motion to Dismiss by no later than August 18,

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(4)

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Defendants may file their reply to the Motion by no later than August 25, 2017; and

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(5)

Plaintiff shall maintain its right to amend its Complaint without leave of Court until

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the hearing on the Motion to Dismiss be continued to August 31, 2017;

6 August 18, 2017.
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IT IS SO STIPULATED.

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9 Dated: July 19, 2017

Respectfully submitted,

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/s/ Rick C. Chang

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Rick C. Chang (SBN 209515)
[e-mail]
Duane H. Mathiowetz (SBN 111831)
[e-mail]
FOLEY & LARDNER LLP
555 California Street, #1700
San Francisco, CA 94104

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Counsel for Zhangyi Zhong and
Dreamworld USA Inc.

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/s/ John-Paul S. Deol

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Jennifer G. Redmond (SBN 144790)
[e-mail]
Paul S. Cowie (SBN 250131)
[e-mail]
John-Paul S. Deol (SBN 284893)
[e-mail]
SHEPPARD, MULLIN, RICHTER &
HAMPTON LLP
Four Embarcadero Center, 17th Floor
San Francisco, CA 94111-4109

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Counsel for Meta Company

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-2SMRH:483499192.2

Case No.

STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES RE MOTION FOR
EXPEDITED DISCOVERY AND MOTION TO DISMISS

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[PROPOSED] ORDER

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3 PURSUANT TO THE PARTIES’ STIPULATION, IT IS SO ORDERED.
for motion to dismiss due 8/10/17.

Reply due 8/17/17.

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______________________________________
Hon. Edward M. Chen ORDERED
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U.S. District IT IS S
Judge
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UNIT
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7/19/17

7 Dated: ______________

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Opposition

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-3SMRH:483499192.2

Case No.

STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES RE MOTION FOR
EXPEDITED DISCOVERY AND MOTION TO DISMISS