Rearden LLC et al v. Crystal Dynamics, Inc. et al

Filing 155

STIPULATION AND ORDER re 150 STIPULATION WITH PROPOSED ORDER re 128 Administrative Motion to File Under Seal re Plaintiffs' Opposition to Defendants' Renewed Motion for Summary Judgment filed by Rearden Mova LLC, Rearden LLC. Signed by Judge Jon S. Tigar on February 6, 2019. (wsn, COURT STAFF) (Filed on 2/6/2019)

1 RIMON, P.C.
Karineh Khachatourian (CA SBN 202634)
2 RIMON, P.C.
Karineh Khachatourian (CA SBN 202634)
3 [e-mail]
Nikolaus A. Woloszczuk (CA SBN 286633)
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2479 E. Bayshore Road, Suite 210
5 Palo Alto, CA 94303
Telephone: [phone]
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Facsimile: [phone]
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STEVE W. BERMAN (pro hac vice)
[e-mail]
MARK S. CARLSON (pro hac vice)
[e-mail]
HAGENS BERMAN SOBOL
SHAPIRO LLP
1301 2nd Avenue, Suite 2000
Seattle, Washington 98101
Telephone:
[phone]
Facsimile:
[phone]

8 Attorneys for Defendants
SQUARE ENIX, INC. and
9 CRYSTAL DYNAMICS, INC.

RIO S. PIERCE (SBN 298297)
[e-mail]
HAGENS BERMAN SOBOL
SHAPIRO LLP
715 Hearst Avenue, Suite 202
Berkeley, California 94710
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Plaintiffs
REARDEN LLC and
REARDEN MOVA LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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REARDEN LLC and REARDEN MOVA
LLC,
Plaintiffs,

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v.
CRYSTAL DYNAMICS, INC., a California
corporation, SQUARE ENIX, INC., a
Washington Corporation,

Case No. 3:17-cv-04187-JST
JOINT STIPULATION AND
[PROPOSED] ORDER REGARDING
PLAINTIFFS’ OPPOSITION TO
DEFENDANTS’ RENEWED MOTION
FOR SUMMARY JUDGMENT
Judge:

Hon. Jon S. Tigar

Defendants.

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Error! Unknown document property name.

JOINT STIPULATION AND [PROPOSED] ORDER REGARDING PLAINTIFFS’ OPPOSITION TO
DEFENDANTS’ RENEWED MOTION FOR SUMMARY JUDGMENT
CASE NO. 3:17-CV-04187-JST

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STIPULATION
Plaintiffs and Defendants in the above-captioned action, by and through their counsel of

3 record, stipulate as follows:
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WHEREAS, on January 22, 2019, Rearden filed its papers in Opposition to Defendants

5 Renewed Motion for Summary judgment;
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WHEREAS, among those papers was the Declaration of Stephen G. Perlman (Dkt. 128-

7 06), which contained certain typographical errors that Plaintiffs wish to remedy;
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WHEREAS, among those papers was the Declaration of Mark Carlson attaching among

9 other exhibits four contracts as Exhibits A, B, C, and D (Dkt. 128-07, 8, 9, 10), which contracts
10 had been previously filed in redacted form as Exhibits G, H, I, and J to the Declaration of Karineh
11 Khachatourian (Dkt. 122-12, 14, 16, 18), and Defendants would like to substitute redacted copies
12 of the Khachatourian exhibits for the non-redacted Carlson exhibits;
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NOW THEREFORE, for good cause, the parties stipulate as follows:

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[1]

The parties agree that Rearden may file a Corrected Declaration of Stephen G.

15 Perlman, and that the Clerk may substitute the Corrected Declaration for its originally filed
16 counterpart at Dkt. 128-06;
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[2]

The parties agree that Rearden may file amended redacted Exhibits A, B, C, and D

18 of the originally filed Declaration of Mark Carlson (Dkt. 128-7, 8, 9,10), and that the Clerk may
19 substitute the amended redacted exhibits filed as Dkt. 144-5 for their originally filed counterparts.
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IT IS SO STIPULATED.

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RIMON, P.C.

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Dated: February 1, 2019

By:

/s/
Karineh Khachatourian
Karineh Khachatourian
Nikolaus A. Woloszczuk
Attorneys for Defendants,
SQUARE ENIX, INC. and
CRYSTAL DYNAMICS, INC.

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JOINT STIPULATION AND [PROPOSED] ORDER REGARDING PLAINTIFFS’ OPPOSITION TO
DEFENDANTS’ RENEWED MOTION FOR SUMMARY JUDGMENT
CASE NO. 3:17-CV-04187-JSTError! Unknown document property name.

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HAGENS BERMAN SOBOL SHAPIRO

2 Dated: February 1, 2019
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By:

/s/
Mark Carlson
Steve W. Berman (Pro Hac Vice)
Mark S. Carlson (Pro Hac Vice)
Attorneys for Plaintiffs,
REARDEN LLC and
REARDEN MOVA LLC

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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February 6
10 DATED: _______________, 2019
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The Honorable Jon S. Tigar

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JOINT STIPULATION AND [PROPOSED] ORDER REGARDING PLAINTIFFS’ OPPOSITION TO
DEFENDANTS’ RENEWED MOTION FOR SUMMARY JUDGMENT
CASE NO. 3:17-CV-04187-JSTError! Unknown document property name.

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CIVIL LOCAL RULE 5-1 ATTESTATION

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I, Mark Carlson, am the ECF user whose credentials were utilized in the electronic filing of

3 this document. In accordance with Civil Local Rule 5-1(i)(3), I hereby attest that Karineh
4 Khachatourian concurred in the filing of this document.
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/s/ Mark Carlson

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JOINT STIPULATION AND [PROPOSED] ORDER REGARDING PLAINTIFFS’ OPPOSITION TO
DEFENDANTS’ RENEWED MOTION FOR SUMMARY JUDGMENT
CASE NO. 3:17-CV-04187-JSTError! Unknown document property name.