Meta Company v. Zhong et al
Filing
50
STIPULATION AND ORDER re 49 TO EXTEND DEADLINES RE MOTION TO DISMISS filed by Meta Company. Responses due by 8/24/2017. Replies due by 8/31/2017. Motion Hearing set for 9/14/2017 01:30 PM in Courtroom 5, 17th Floor, San Francisco before Edward M. Chen. Signed by Judge Edward M. Chen on 8/1/17. (bpfS, COURT STAFF) (Filed on 8/1/2017)
1 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
2
3
4
5
6
7
8
A Limited Liability Partnership
Including Professional Corporations
JENNIFER G. REDMOND, Cal. Bar No. 144790
jredmond@sheppardmullin.com
PAUL S. COWIE, Cal. Bar No. 250131
pcowie@sheppardmullin.com
JOHN-PAUL S. DEOL, Cal. Bar No. 284893
jdeol@sheppardmullin.com
Four Embarcadero Center, 17th Floor
San Francisco, CA 94111-4109
Telephone:
415.434.9100
Facsimile:
415.434.3947
9 Attorneys for Plaintiff
10
META COMPANY
11
UNITED STATES DISTRICT COURT
12
NORTHERN DISTRICT OF CALIFORNIA
13
SAN FRANCISCO DIVISION
14 META COMPANY, a Delaware corporation,
Case No. 3:17-cv-03259-EMC
15
STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINES RE
MOTION TO DISMISS
16
Plaintiff,
v.
17
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.
21
22
23
24
25
26
27
28
Case No. 3:17-cv-03259-EMC
SMRH:483597469.1
STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES RE MOTION TO
DISMISS
1
Pursuant to Local Rule 6-2 of the Northern District of California, Defendants Zhangyi Zhong
2 and Dreamworld USA Inc. (“Defendants”) and Plaintiff Meta Company (“Meta” or “Plaintiff”)
3 hereby stipulate to move the hearing date and extend the briefing deadlines on Defendant’s Motion
4 to Dismiss (“Motion to Dismiss”) (Dkt. No. 38).
5
WHEREAS, the Parties are currently attempting to informally resolve the above-captioned
6 lawsuit and are set to begin those discussions on August 9, 2017 (Deol Decl., ¶ 2);
7
WHEREAS, the Parties wish to avoid spending additional time and effort in briefing and
8 attending a hearing on the Motion to Dismiss in the event this case can be informally resolved (Deol
9 Decl., ¶ 3);
10
WHEREAS the Motion to Dismiss is now set for hearing on August 31, 2017;
11
WHEREAS, Plaintiff’s opposition to the Motion to Dismiss is currently due on August 10,
12 2017, only one day after the Parties are set to begin meeting in an attempt to informally resolve the
13 above-captioned matter;
14
WHEREAS, Defendants’ reply in support of the Motion to Dismiss is currently due on
15 August 17, 2017;
16
WHEREAS, on July 20, 2017 the Court granted an extension of the hearing dates and
17 briefing schedule on the Motion to Dismiss in Dkt. No. 47 (Deol Decl., ¶ 4);
18
WHEREAS, counsel for both Parties agree that the requested extension would not affect any
19 other deadlines in this case (Deol Decl., ¶ 5)
20
WHEREAS, counsel for both Parties agree that a further extension of the Motion to Dismiss
21 hearing and briefing schedule would be prudent; and
22
WHEREAS, Civil Local Rule 6-2(a) of the Northern District of California states, “The
23 parties may file a stipulation … requesting an order changing time that would affect the date of an
24 event or deadline already fixed by Court order, or that would accelerate or extend time frames set
25 in the Local Rules or in the Federal Rules.”
26
///
27
///
28
///
SMRH:483597469.1
-1-
Case No. 3:17-cv-03259-EMC
STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES RE MOTION TO
DISMISS
NOW, THEREFORE, in consideration of the foregoing, the Parties agree and hereby
1
2 stipulate that:
3
(1)
the hearing on the Motion to Dismiss be continued to September 14, 2017;
4
(2)
Plaintiff may file its opposition to the Motion to Dismiss by no later than August 24,
6
(3)
Defendants may file their reply to the Motion by no later than August 31, 2017; and
7
(4)
Plaintiff shall maintain its right to amend its Complaint without leave of Court until
5 2017;
8 August 24, 2017.
9
IT IS SO STIPULATED.
10
11 Dated: July 31, 2017
Respectfully submitted,
12
/s/ Rick C. Chang
13
Rick C. Chang (SBN 209515)
rchang@foley.com
Duane H. Mathiowetz (SBN 111831)
dmathiowetz@foley.com
FOLEY & LARDNER LLP
555 California Street, #1700
San Francisco, CA 94104
14
15
16
17
Counsel for Zhangyi Zhong and
Dreamworld USA Inc.
18
19
/s/ John-Paul S. Deol
20
25
Jennifer G. Redmond (SBN 144790)
jredmond@sheppardmullin.com
Paul S. Cowie (SBN 250131)
pcowie@sheppardmullin.com
John-Paul S. Deol (SBN 284893)
jdeol@sheppardmullin.com
SHEPPARD, MULLIN, RICHTER &
HAMPTON LLP
Four Embarcadero Center, 17th Floor
San Francisco, CA 94111-4109
26
Counsel for Meta Company
21
22
23
24
27
28
SMRH:483597469.1
-2-
Case No. 3:17-cv-03259-EMC
STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES RE MOTION TO
DISMISS
1
[PROPOSED] ORDER
2
3 PURSUANT TO THE PARTIES’ STIPULATION, IT IS SO ORDERED.
4
5
S
ER
12
R NIA
A
H
11
dwa
Judge E
FO
RT
10
hen
rd M. C
NO
9
______________________________________
RED
Hon. EdwardS SO ORDE
M. Chen
IT I
U.S. District Judge
LI
8
UNIT
ED
8/1/17
7 Dated: ______________
RT
U
O
6
S DISTRICT
TE
C
TA
N
F
D IS T IC T O
R
C
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
SMRH:483597469.1
-3-
Case No. 3:17-cv-03259-EMC
STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES RE MOTION TO
DISMISS
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?