Sweet et al v. Google, Inc.
Filing
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STIPULATION AND ORDER to vacate 11/9/17 motion hearing 10/11/17 and reset CMC from 12/21/17 to 3/1/18 re 21 Stipulation. Signed by Judge Edward M. Chen on 10/6/17. (bpfS, COURT STAFF) (Filed on 10/6/2017)
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Todd M. Friedman (216752)
Adrian R. Bacon (280332)
Law Offices of Todd M. Friedman, P.C.
21550 Oxnard Street, Suite 780
Woodland Hills, CA 91367
Phone: 877-206-4741
Fax: 866-633-0228
tfriedman@toddflaw.com
abacon@toddflaw.com
Attorneys for Plaintiff
Attorneys for Plaintiff, JAMES SWEET; CHUCK MERE; ZOMBIE GO BOOM,
LLC, DBA ZOMBIEGOBOOM
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION
JAMES SWEET; CHUCK MERE;
ZOMBIE GO BOOM, LLC, DBA
ZOMBIEGOBOOM,
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Plaintiff,
vs.
GOOGLE, INC. DBA YOUTUBE,
Defendant.
Case No. 3:17-cv-03953-EMC
[Hon. Edward M. Chen]
STIPULATION CONTINUING
PLAINTIFF’S DEADLINE TO FILE A
FIRST AMENDED COMPLAINT
Complaint Filed: July 13, 2017
Current Motion Hearing Date:
November 9, 2017
New Date: TBD
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JOINT STIPULATION EXTENDING PLAINTIFF’S DEADLINE
TO FILE FIRST AMENDED COMPLAINT
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Plaintiff, JAMES SWEET; CHUCK MERE; ZOMBIE GO BOOM, LLC,
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DBA ZOMBIEGOBOOM, (“Plaintiff”), and Defendant, GOOGLE, INC.
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(“Defendant”), hereby agree and stipulate as follows:
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WHEREAS, on July 13, 2017, Plaintiff filed a purported Class Action
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Complaint (the “Complaint”) against Defendant, and served the Complaint on
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Defendant on or about August 4, 2017;
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WHEREAS, on August 14, 2017, the parties entered in a stipulation
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extending Defendant’s deadline to respond to the complaint to September 25,
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2017;
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WHEREAS, Defendant filed, on September 25, 2017, a motion to dismiss
Plaintiff’s complaint;
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WHEREAS, Pursuant to Northern District of California Local Rule 7-3(a),
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Plaintiff’s deadline to file an opposition to Defendant’s motion to dismiss is
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October 9, 2017, only 14 days after Defendant’s filing of their motion to dismiss;
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WHEREAS, Plaintiff plans to file a first amended complaint to address the
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deficiencies addressed in Defendant’s motion to dismiss the complaint, the parties
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wish to continue plaintiff’s deadline to file their opposition to Defendant’s motion
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to dismiss the complaint, to allow time to file a first amended complaint and to
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research and respond adequately to Defendant’s issues raised in their motion to
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dismiss;
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WHEREAS, the parties have agreed to extend the deadline to October 26,
2017 for Plaintiff to file a first amended complaint;
WHEREAS, the parties have agreed to extend the deadline to November 30,
2017 for Defendant to respond to the first amended complaint;
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WHEREAS, the parties have agreed that Plaintiff will submit any
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oppositions to Defendant’s responsive pleadings under Northern District of
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California Local Rule 7-3(a); and
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JOINT STIPULATION EXTENDING PLAINTIFF’S DEADLINE
TO FILE SECOND AMENDED COMPLAINT
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Whereas; the parties will request this Honorable Court to vacate the
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November 9, 2017 hearing date for Defendant’s Motion to Dismiss the Complaint;
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and
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WHEREAS, the parties request that the case management conference
currently scheduled for December 21, 2017 be continued to February 22, 2018;
Thus, it is hereby stipulated that:
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1. Plaintiff’s deadline to file the first amended complaint is continued to
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October 26, 2017, Defendant’s deadline to submit responsive pleadings
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is continued to November 30, 2017, and Plaintiff’s deadline to submit
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an opposition to Plaintiff’s responsive pleadings is continued, pursuant
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to Northern District of California Local Rule 7-3(a), based on the date
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Defendant’s response is filed; and
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2. The November 9, 2017 hearing date for Defendant’s Motion to Dismiss
the Complaint is vacated; and
3. The case management conference currently scheduled for December 21,
2018 is continued to February 22, 2018. March 1, 2018 at 9:30 a.m.
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Dated: October 6, 2017
Law Offices of Todd M. Friedman, P.C.
By:_/s/ Todd M. Friedman____
Todd M. Friedman, Esq.
Adrian R. Bacon, Esq.
Attorneys for Plaintiff
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Dated: October 6, 2017 WILSON SONSINI GOODRICH & ROSATI, P.C.
By:_/s/ Maura L. Rees______
Maura L. Rees
Attorneys for Defendant
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JOINT STIPULATION EXTENDING PLAINTIFF’S DEADLINE
TO FILE SECOND AMENDED COMPLAINT
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Judge E
ER
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R NIA
. Chen
Hon. Edward rM. Chen
dwa d M
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NO
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__________________
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DERED
SO OR ED
IT IS
DIFI
AS MO
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
UNIT
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JOINT STIPULATION EXTENDING PLAINTIFF’S DEADLINE
TO FILE SECOND AMENDED COMPLAINT
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Signature Certification
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Pursuant to Section 2(f)(4) of the Electronic Case Filing Administrative
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Policies and Procedures Manual, I hereby certify that the content of this document
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is acceptable to Maura L. Rees, and that I have Ms. Rees’s authorization to affix her
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electronic signature to this document.
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Dated: October 6, 2017
Law Offices of Todd M. Friedman, P.C.
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By:_/s/ Todd M. Friedman____
Todd M. Friedman, Esq.
Adrian R. Bacon, Esq.
Attorneys for Plaintiff
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JOINT STIPULATION EXTENDING PLAINTIFF’S DEADLINE
TO FILE SECOND AMENDED COMPLAINT
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CERTIFICATE OF SERVICE
Filed electronically on October 6, 2017, with:
United States District Court CM/ECF system
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Notification sent electronically on October 6, 2017, to:
Honorable Judge Edward M. Chen
United States District Court
Northern District of California, San Francisco Division
And to all counsel of record
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s/Todd M. Friedman
Todd M. Friedman, Esq.
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JOINT STIPULATION EXTENDING PLAINTIFF’S DEADLINE
TO FILE SECOND AMENDED COMPLAINT
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