Sines et al v. Kessler et al

Filing 13

STIPULATION AND ORDER TO EXTEND TIME TO FILE REPLY IN SUPPORT OF MOTION TO QUASH: granting 12 Stipulation. Set/Reset Deadlines as to 1 MOTION to Quash. Replies due by 6/27/2018. Signed by Chief Magistrate Judge Joseph C. Spero on 6/13/2018. (tlhS, COURT STAFF) (Filed on 6/14/2018)

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Marc J. Randazza, CA Bar No. 269535
Alex J. Shepard, CA Bar No. 295058
RANDAZZA LEGAL GROUP, PLLC
2764 Lake Sahara Drive, Suite 109
Las Vegas, Nevada 89117
Tel: [phone]
[e-mail]
Attorneys for Movant,
Jane Doe

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Sean P. Rodriguez (SBN 262437)
BOIES, SCHILLER & FLEXNER LLP
1999 Harrison Street, Suite 900
Oakland, CA 94612
Phone: [phone]
Facsimile: 510/874-1460
[e-mail]

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See signature page for complete list of counsel.

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Attorney for Respondents, the
Plaintiffs in the Underlying Action

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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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IN RE: Motion of Non-Party JANE DOE

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ELIZABETH SINES, et al.,

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Plaintiffs,

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Case No. 3:18-mc-80080-JCS
STIPULATED
REQUEST
TO
EXTEND TIME TO FILE REPLY IN
SUPPORT OF MOTION TO QUASH
A
FOREIGN
SUBPOENA;
[PROPOSED] ORDER

v.
JASON KESSLER, et al.,

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Defendant.

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-1Request for Extension of Time to File Reply in Support of Motion to Quash
3:18-mc-80080-JCS

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STIPULATION

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Pursuant to Federal Rule of Civil Procedure 6(b), and Civil Local Rule 6-2, counsel on

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both sides of this action to quash a foreign subpoena stipulate to an order extending the time to file

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a reply in support of the motion to quash by two weeks. The current deadline to file a reply is June

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13, 2018, and the proposed new deadline is June 27, 2018.

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The underlying action was brought by Elizabeth Sines, et al. (“Respondents”) on October

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11, 2017 in the Western District of Virginia, where it remains pending. (Sines v. Kessler, No. 17-

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CV-72 (W.D. Va.).) Plaintiffs issued a subpoena to non-party Discord Inc. on January 2, 2018,

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returnable in this District. Non-party movant Jane Doe filed the instant action to quash that

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subpoena on May 16, 2018. After seeking and obtaining an extension of time to file its opposition

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brief, Respondents filed their opposition brief on June 6, 2018.

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Movant’s current deadline to file a reply in support of the motion to quash is June 13, 2018.

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Movant requests a two-week extension of time to file the reply brief, meaning the deadline will

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become June 27, 2018. Respondents stipulate to the new due date.

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Aside from Respondents’ stipulated request for additional time to file their opposition brief,

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no other requests for an extension have been made in this action. There is no hearing or argument

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date scheduled in this case that would be affected by the request. The accompanying declaration

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of Alex J. Shepard states Respondents’ reasons for the requested change. (Civ. L.R. 6-2(a)(1).)

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-2Request for Extension of Time to File Reply in Support of Motion to Quash
3:18-mc-80080-JCS

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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Dated: June 12, 2018

Respectfully submitted,

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RANDAZZA LEGAL GROUP, PLLC

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By: /s/ Alex J. Shepard
Marc J. Randazza (SBN 269535)
Alex J. Shepard (SBN 295058)
2764 Lake Sahara Drive, Suite 109
Las Vegas, NV 89117
Phone: [phone]
[e-mail]

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Attorneys for Movant,
Jane Doe

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Dated: June 12, 2018

BOIES SCHILLER FLEXNER LLP

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By: /s/ Sean P. Rodriguez
Sean P. Rodriguez (SBN 262437)
1999 Harrison Street, Suite 900
Oakland, CA 94612
Phone: [phone]
Facsimile: 510/874-1460
[e-mail]
Joshua J. Libling (admitted pro hac vice)
575 Lexington Avenue
New York, NY 10022
Phone: [phone]
Fax: [phone]
[e-mail]

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Attorney for Respondents, the
Plaintiffs in the Underlying Action

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-3Request for Extension of Time to File Reply in Support of Motion to Quash
3:18-mc-80080-JCS

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FILER’S ATTESTATION

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I, Alex J. Shepard, am the ECF user whose identification and password are being used to

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file this Stipulation. In compliance with Civil Local Rule 5-1(i)(3), I hereby attest that the

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signatories on this document have concurred in this filing.

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/s/ Alex J. Shepard
Alex J. Shepard

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-4Request for Extension of Time to File Reply in Support of Motion to Quash
3:18-mc-80080-JCS

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: June 13, 2018

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Hon. Joseph C. Spero
United States Magistrate Judge

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-5Request for Extension of Time to File Reply in Support of Motion to Quash
3:18-mc-80080-JCS

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Case No. 3:18-mc-80080-JCS
CERTIFICATE OF SERVICE

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I HEREBY CERTIFY that on this 12th day of June 2018, I electronically filed the foregoing

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document with the Clerk of the Court using CM/ECF. I further certify that a true and correct copy

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of the foregoing document being served via transmission of Notices of Electronic Filing generated

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by CM/ECF upon counsel for Respondents, the Plaintiffs in the Underlying Action:

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Sean P. Rodriguez
BOIES SCHILLER FLEXNER LLP
1999 Harrison Street, Suite 900
Oakland, CA 94612
Attorneys for Respondents,
the Plaintiffs in the Underlying Action
I further certify that on this 12th day of June 2018, I served a true and correct copy of the
foregoing document upon the following participants, listed below, via electronic mail:
Catherine M. del Fierro
PERKINS COIE LLP
1201 Third Ave., Ste. 4900
Seattle, WA 98101
[e-mail]
Attorney for Discord, Inc.
Respectfully submitted,
p
y

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Employee,
Randazza Legal Group, PLLC

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-6Request for Extension of Time to File Reply in Support of Motion to Quash
3:18-mc-80080-JCS