Sweet et al v. Google, Inc.

Filing 22

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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1 2 3 4 5 6 7 8 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 9 UNITED STATES DISTRICT COURT 10 11 12 13 NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION JAMES SWEET; CHUCK MERE; ZOMBIE GO BOOM, LLC, DBA ZOMBIEGOBOOM, 14 15 16 17 18 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 19 20 21 22 23 24 25 26 27 28 JOINT STIPULATION EXTENDING PLAINTIFF’S DEADLINE TO FILE FIRST AMENDED COMPLAINT -1- 1 Plaintiff, JAMES SWEET; CHUCK MERE; ZOMBIE GO BOOM, LLC, 2 DBA ZOMBIEGOBOOM, (“Plaintiff”), and Defendant, GOOGLE, INC. 3 (“Defendant”), hereby agree and stipulate as follows: 4 WHEREAS, on July 13, 2017, Plaintiff filed a purported Class Action 5 Complaint (the “Complaint”) against Defendant, and served the Complaint on 6 Defendant on or about August 4, 2017; 7 WHEREAS, on August 14, 2017, the parties entered in a stipulation 8 extending Defendant’s deadline to respond to the complaint to September 25, 9 2017; 10 11 WHEREAS, Defendant filed, on September 25, 2017, a motion to dismiss Plaintiff’s complaint; 12 WHEREAS, Pursuant to Northern District of California Local Rule 7-3(a), 13 Plaintiff’s deadline to file an opposition to Defendant’s motion to dismiss is 14 October 9, 2017, only 14 days after Defendant’s filing of their motion to dismiss; 15 WHEREAS, Plaintiff plans to file a first amended complaint to address the 16 deficiencies addressed in Defendant’s motion to dismiss the complaint, the parties 17 wish to continue plaintiff’s deadline to file their opposition to Defendant’s motion 18 to dismiss the complaint, to allow time to file a first amended complaint and to 19 research and respond adequately to Defendant’s issues raised in their motion to 20 dismiss; 21 22 23 24 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; 25 WHEREAS, the parties have agreed that Plaintiff will submit any 26 oppositions to Defendant’s responsive pleadings under Northern District of 27 California Local Rule 7-3(a); and 28 JOINT STIPULATION EXTENDING PLAINTIFF’S DEADLINE TO FILE SECOND AMENDED COMPLAINT -2- 1 Whereas; the parties will request this Honorable Court to vacate the 2 November 9, 2017 hearing date for Defendant’s Motion to Dismiss the Complaint; 3 and 4 5 6 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: 7 1. Plaintiff’s deadline to file the first amended complaint is continued to 8 October 26, 2017, Defendant’s deadline to submit responsive pleadings 9 is continued to November 30, 2017, and Plaintiff’s deadline to submit 10 an opposition to Plaintiff’s responsive pleadings is continued, pursuant 11 to Northern District of California Local Rule 7-3(a), based on the date 12 Defendant’s response is filed; and 13 14 15 16 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. 17 18 19 20 21 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 22 23 24 25 26 Dated: October 6, 2017 WILSON SONSINI GOODRICH & ROSATI, P.C. By:_/s/ Maura L. Rees______ Maura L. Rees Attorneys for Defendant 27 28 JOINT STIPULATION EXTENDING PLAINTIFF’S DEADLINE TO FILE SECOND AMENDED COMPLAINT -3- Judge E ER 8 A H 7 R NIA . Chen Hon. Edward rM. Chen dwa d M RT 6 NO 5 __________________ FO 4 DERED SO OR ED IT IS DIFI AS MO LI 3 PURSUANT TO STIPULATION, IT IS SO ORDERED. UNIT ED 2 RT U O S 1 S DISTRICT TE C TA N F D IS T IC T O R C 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JOINT STIPULATION EXTENDING PLAINTIFF’S DEADLINE TO FILE SECOND AMENDED COMPLAINT -4- Signature Certification 1 2 3 Pursuant to Section 2(f)(4) of the Electronic Case Filing Administrative 4 Policies and Procedures Manual, I hereby certify that the content of this document 5 is acceptable to Maura L. Rees, and that I have Ms. Rees’s authorization to affix her 6 electronic signature to this document. 7 Dated: October 6, 2017 Law Offices of Todd M. Friedman, P.C. 8 9 10 11 By:_/s/ Todd M. Friedman____ Todd M. Friedman, Esq. Adrian R. Bacon, Esq. Attorneys for Plaintiff 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JOINT STIPULATION EXTENDING PLAINTIFF’S DEADLINE TO FILE SECOND AMENDED COMPLAINT -5- 1 2 3 CERTIFICATE OF SERVICE Filed electronically on October 6, 2017, with: United States District Court CM/ECF system 4 5 6 7 8 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 9 10 s/Todd M. Friedman Todd M. Friedman, Esq. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JOINT STIPULATION EXTENDING PLAINTIFF’S DEADLINE TO FILE SECOND AMENDED COMPLAINT -6-

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