Sweet et al v. Google, Inc.
Filing
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STIPULATION AND ORDER re 31 re 29 MOTION to Dismiss the First Amended Complaint filed by Chuck Mere, James Sweet, Zombie Go Boom, LLC dba ZombieGoBoom. Responses due by 1/25/2018. Replies due by 2/8/2018. Motion He aring set for 3/1/2018 01:30 PM in Courtroom 5, 17th Floor, San Francisco before Judge Edward M. Chen. Case Management Statement due by 4/26/2018. Initial Case Management Conference set for 5/3/2018 09:30 AM in Courtroom 5, 17th Floor, San Francisco. Signed by Judge Edward M. Chen on 12/1/17. (bpfS, COURT STAFF) (Filed on 12/1/2017)
Case 3:17-cv-03953-EMC Document 31 Filed 12/01/17 Page 1 of 6
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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, LLC; YOUTUBE, LLC; and
DOES 1-10, inclusive,
Defendant.
Case No. 3:17-cv-03953-EMC
[Hon. Edward M. Chen]
STIPULATION CONTINUING
PLAINTIFF’S DEADLINE TO FILE
OPPOSITION TO DEFENDANT’S
MOTION TO DISMISS
Complaint Filed: July 13, 2017
Current Motion Hearing Date:
January 4, 2018
New Date: TBD
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JOINT STIPULATION EXTENDING PLAINTIFF’S DEADLINE
TO FILE FIRST AMENDED COMPLAINT
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Case 3:17-cv-03953-EMC Document 31 Filed 12/01/17 Page 2 of 6
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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 October 26, 2017, Plaintiff filed their First Amended
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Complaint (“FAC”) against Defendant, and served the FAC on Defendant on or
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about October 26, 2017.
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WHEREAS, Defendant filed, on November 30, 2017, a motion to dismiss
Plaintiff’s FAC;
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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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December 14, 2017, only 14 days after Defendant’s filing of their motion to
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dismiss;
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WHEREAS, Defendant’s Motion to Dismiss is scheduled to be heard on
January 4, 2018;
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WHEREAS, Plaintiff’s lead counsel will be out of the country for a period
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of time encompassing the Motion to Dismiss’s hearing date, the parties wish to
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continue Plaintiff’s deadline to file their opposition to Defendant’s Motion to
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Dismiss the complaint and to research and respond adequately to Defendant’s
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issues raised in their motion to dismiss;
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WHEREAS, the parties have agreed to extend the deadline to January 25,
2018 for Plaintiff to file their opposition to Defendant’s Motion to Dismiss;
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WHEREAS, the parties have agreed to extend the deadline to February 8,
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2018 for Defendant to respond to the Plaintiff’s opposition to Defendant’s Motion
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to Dismiss;
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JOINT STIPULATION EXTENDING PLAINTIFF’S DEADLINE
TO FILE THEIR OPPOSITION TO DEFENDANT’S MOTION TO DISMISS
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Case 3:17-cv-03953-EMC Document 31 Filed 12/01/17 Page 3 of 6
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WHEREAS; the parties will request this Honorable Court to vacate the
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January 4, 2018, hearing date for Defendant’s Motion to Dismiss the Complaint
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and set the hearing date for Defendant’s Motion to Dismiss for March 1, 2018; and
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WHEREAS, the parties request that the case management conference
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currently scheduled for March 1, 2018, be continued to May 3, 2018;
Thus, it is hereby stipulated that:
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1. Plaintiff’s deadline to file their opposition to Defendant’s Motion to
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Dismiss is continued to January 25, 2018, and Defendant’s deadline to
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submit a response is continued to February 8, 2018;
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2. The January 4, 2018 hearing date for Defendant’s Motion to Dismiss the
Complaint is continued to March 1, 2018; and
3. The case management conference currently scheduled for March 1,
2018 is continued to May 3, 2018.
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Dated: December 1, 2017
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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: December 1, 2017
P.C.
WILSON SONSINI GOODRICH & ROSATI,
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By:_/s/ Maura L. Rees______
Maura L. Rees
Attorneys for Defendant
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JOINT STIPULATION EXTENDING PLAINTIFF’S DEADLINE
TO FILE THEIR OPPOSITION TO DEFENDANT’S MOTION TO DISMISS
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Case 3:17-cv-03953-EMC Document 31 Filed 12/01/17 Page 4 of 6
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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Hon. Edward M. Chen
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JOINT STIPULATION EXTENDING PLAINTIFF’S DEADLINE
TO FILE THEIR OPPOSITION TO DEFENDANT’S MOTION TO DISMISS
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Case 3:17-cv-03953-EMC Document 31 Filed 12/01/17 Page 5 of 6
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: December 1, 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 THEIR OPPOSITION TO DEFENDANT’S MOTION TO DISMISS
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Case 3:17-cv-03953-EMC Document 31 Filed 12/01/17 Page 6 of 6
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CERTIFICATE OF SERVICE
Filed electronically on December 1, 2017, with:
United States District Court CM/ECF system
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Notification sent electronically on December 1, 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 THEIR OPPOSITION TO DEFENDANT’S MOTION TO DISMISS
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Case 3:17-cv-03953-EMC Document 31-1 Filed 12/01/17 Page 1 of 2
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION
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BOOM, LLC, DBA ZOMBIEGOBOOM,
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Plaintiff,
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vs.
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GOOGLE, LLC; YOUTUBE, LLC; and DOES 115 10, inclusive,
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No.: 3:17-cv-03953-MEJ EMC
[PROPOSED] ORDER GRANTING
STIPULATION TO EXTEND DEADLINE
FOR PLAINTIFF TO FILE THE
OPPOSITION TO DEFENDANT’S
MOTION TO DISMISS
Defendant.
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[PROPOSED] ORDER GRANTING EXTENSION
US_ACTIVE-126011724.1
Case 3:17-cv-03953-EMC Document 31-1 Filed 12/01/17 Page 2 of 2
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Currently before the Court is the Joint Stipulation Between Plaintiff JAMES SWEET; CHUCK
2 MERE; ZOMBIE GO BOOM, LLC, DBA ZOMBIEGOBOOM (“Plaintiff”) and Defendant
3 GOOGLE, LLC; YOUTUBE, LLC (“Defendant”) To Continue The Deadline for Plaintiff to File
4 Their Opposition to Defendant’s Motion to Dismiss, by and through their counsel. Good cause
5 appearing, the Parties’ Joint Stipulation is GRANTED, and IT IS HEREBY ORDERED that the
6 deadlines in this matter will be continued as follows:
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Plaintiff’s Opposition to Defendant’s Motion to Dismiss:
January 25, 2018
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Defendant’s Reply:
February 8, 2018
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Hearing on Motion to Dismiss Complaint:
1:30
March 1, 2018, at _______ p.m.
Case Management Conference:
May 3, 2018 at 9:30 a.m.
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IT IS SO ORDERED
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1st
Dec.
Dated this ______ day of _________, 2017
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Hon. Edward M.
IT IS S
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United States District Judge
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[PROPOSED] ORDER GRANTING EXTENSION
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