Meta Company v. Zhong et al

Filing 54

STIPULATION AND ORDER re 53 TO EXTEND DEADLINES RE MOTION FOR EXPEDITED DISCOVERY AND MOTION TO DISMISS filed by Meta Company.Both motions extended to 10/26/17 at 1:30 p.m. Signed by Judge Edward M. Chen on 8/22/17. (bpfS, COURT STAFF) (Filed on 8/22/2017)

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

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Plaintiff,
v.

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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:483831657.1

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 have tentatively resolved the above-captioned lawsuit (Deol Decl.,

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7 ¶ 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, given that the case
10 has tentatively been resolved (Deol Decl., ¶ 3);
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WHEREAS the Expedited Discovery Motion is set for hearing on August 24, 2017;

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WHEREAS the Motion to Dismiss is set for hearing on September 14, 2017;

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WHEREAS, Plaintiff’s opposition to the Motion to Dismiss is currently due on August 24,

14 2017;
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WHEREAS, Defendants’ reply in support of the Motion to Dismiss is currently due on

16 August 31, 2017;
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WHEREAS, there have been two previous extensions of time while the Parties have

18 endeavored to settle this matter (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)

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SMRH:483831657.1

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the hearing on the Expedited Discovery Motion be continued to October 19, 2017;

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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)

the hearing on the Motion to Dismiss be continued to October 26, 2017;

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(3)

Plaintiff may file its opposition to the Motion to Dismiss by no later than October 5,

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(4)

Defendants may file their reply to the Motion by no later than October 12, 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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6 October 5, 2017.
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IT IS SO STIPULATED.

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9 Dated: August 21, 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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SMRH:483831657.1

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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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[PROPOSED] ORDER

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3 PURSUANT TO THE PARTIES’ STIPULATION, IT IS SO ORDERED. (as amended
on p. 1)

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______________________________________
RED
Hon. Edward M.RDE
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UNIT
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8/22/17
7 Dated: ______________

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

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