Poinsignon v. Imperva, Inc. et al

Filing 19

STIPULATION AND ORDER re 18 to Continue Motion to Dismiss Hearing and Initial Case Management Conference filed by Imperva, Inc. Case Management Statement due by 1/18/2018. Initial Case Management Conference reset for 1/25/2018 01:30 PM in Courtroom 5, 17th Floor, San Francisco. Motion Hearing set for 1/25/2018 01:30 PM in Courtroom 5, 17th Floor, San Francisco before Judge Edward M. Chen. Signed by Judge Edward M. Chen on 12/6/17. (bpf, COURT STAFF) (Filed on 12/6/2017)

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LAURENCE F. PULGRAM (CSB No. 115163)
[e-mail]
SHANNON E. TURNER (CSB No. 310121)
[e-mail]
FENWICK & WEST LLP
555 California Street, 12th Floor
San Francisco, CA 94104
Telephone:
415.875.2300
Facsimile:
415.281.1350
ATTORNEYS FOR DEFENDANT
IMPERVA, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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MOUNTAIN VIEW

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ATTORNEYS AT LAW

F ENWICK & W EST LLP

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JULIEN POINSIGNON, on behalf of himself, all
others similarly situated,
Plaintiff,

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v.

Case No.: 3:17-cv-05653-EMC
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE MOTION TO
DISMISS HEARING AND INITIAL
CASE MANAGEMENT CONFERENCE

IMPERVA, INC., a Delaware corporation; and
DOES 1 through 100, inclusive,
Defendants.
Pursuant to Federal Rule of Civil Procedure 6(b) and Local Rules 6-1(b) and 6-2, Plaintiff

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Julien Poinsignon (“Plaintiff”) and Defendant Imperva, Inc. (“Imperva”) by and through their

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respective counsel, (collectively, the “Parties”), hereby agree and stipulate, and request an order

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from the Court to reschedule the hearing on Imperva’s Motion to Dismiss and the Initial Case

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Management Conference currently set for January 4, 2018, and adjusting accordingly the related

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deadlines. In support of this request, the parties stipulate as follows:

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WHEREAS, Imperva filed a Motion to Dismiss Plaintiff’s Complaint on November 6,
2017, with a hearing date of December 14, 2017, which Motion is now fully briefed;

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WHEREAS, on November 22, 2017, the Court rescheduled the hearing for January 4,

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2018 at 1:30 pm and the Initial Case Management Conference is scheduled for the same time;

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STIPULATION TO CONTINUE HEARING
AND CMC

CASE NO.: 3:17-CV-05653-EMC

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WHEREAS, Imperva’s lead trial counsel has family travel scheduled on January 4, 2018,

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that would make him unavailable for the Motion to Dismiss hearing and Initial Case Management

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Conference on that date;

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WHEREAS, the Parties have conferred and agree that this stipulated extension will not

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cause prejudice to any of the Parties, and that there is good cause for the requested continuance,

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and have, subject to the Court’s convenience, agreed to a hearing date of January 25, 2018;

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WHEREAS, the Parties previously stipulated once to extend the time for Imperva to

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respond to the Complaint (Dkt. 7), and there have been no other time modifications in this case by

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stipulation or Court order; and

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MOUNTAIN VIEW

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ATTORNEYS AT LAW

F ENWICK & W EST LLP

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WHEREAS, this short extension will not substantively affect the overall case schedule,
particularly given the preliminary stage of this litigation.
NOW THEREFORE, the Parties hereby stipulate and agree that the Motion to Dismiss

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hearing and Initial Case Management Conference set for January 4, 2018 be rescheduled to

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January 25, 2018 and that all corresponding deadlines be extended accordingly. The Parties

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respectfully request that the Court enter this schedule as an accommodation, or such other as the

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Court finds convenient, in the attached proposed order.

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Dated: December 4, 2017

FENWICK & WEST LLP

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By: /s/ Laurence F. Pulgram
Laurence F. Pulgram

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Attorneys for Defendant
IMPERVA, INC.

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Dated: December 4, 2017

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SETAREH LAW GROUP

By: /s/ H. Scott Leviant
H. Scott Leviant

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Attorneys for Plaintiff
JULIEN POINSIGNON

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STIPULATION TO CONTINUE HEARING
AND CMC

CASE NO.: 3:17-CV-05653-EMC

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ATTORNEY ATTESTATION
I hereby attest that the concurrence in the filing of this document has been obtained from
its signatory.

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/s/ Laurence F. Pulgram
Laurence F. Pulgram

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ATTORNEYS AT LAW

F ENWICK & W EST LLP

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STIPULATION TO CONTINUE HEARING
AND CMC

CASE NO.: 3:17-CV-05653-EMC

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[PROPOSED] ORDER

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Upon consideration of the Stipulation to Continue Motion to Dismiss Hearing and Initial

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Case Management Conference filed by Plaintiff Julien Poinsignon and Defendant Imperva, Inc.,

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IT IS HEREBY ORDERED as follows:

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1.

The Motion to Dismiss hearing currently scheduled for January 4, 2018 will be

rescheduled to January 25, 2018 at 1:30 pm.
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The Initial Case Management Conference currently scheduled for January 4, 2018

will be rescheduled to January 25, 2018 at 1:30 p.m.
3.

All relevant deadlines set forth in the Case Management Conference Order in

Conference.

Hon. Edward M. Chen
United States District Judge
hen
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ATTORNEYS AT LAW

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12/6
Dated:___________, 2017

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Reassigned Cases are extended in accordance with the new date for the Initial Case Management

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F ENWICK & W EST LLP

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[PROPOSED] ORDER

CASE NO.: 3:17-CV-05653-EMC