Doe v. Roblox Corporation

Filing 32

ORDER granting 31 STIPULATION to continue deadlines as to 25 MOTION to Dismiss. Response due by 1/20/2022. Reply due by 2/4/2022. Hearing remains set for 2/16/2022. Signed by Judge William H. Orrick on 01/11/2022. (jmd, COURT STAFF) (Filed on 1/11/2022)

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1 5 Rafey Balabanian (SBN 315962) rbalabanian@edelson.com Lily Hough (SBN 315277) lhough@edelson.com EDELSON PC 150 California Street, 18th Floor San Francisco, California 94111 Tel: 415.212.9300 Fax: 415.373.9435 6 Attorneys for Plaintiff and the Putative Class 7 ANTHONY J WEIBELL (SBN 238850) WILSON SONSINI GOODRICH & ROSATI Professional Corporation 650 Page Mill Road Palo Alto, CA 94304-1050 Telephone: (650) 493-9300 Facsimile: (650) 565-5100 Email: aweibell@wsgr.com 2 3 4 8 9 10 11 12 Attorneys for Defendant UNITED STATES DISTRICT COURT 13 NORTHERN DISTRICT OF CALIFORNIA 14 SAN FRANCISCO DIVISION 15 16 JANE DOE, Plaintiff, 17 18 19 20 CASE NO.: 3:21-cv-03943-WHO v. ROBLOX CORPORATION, STIPULATED REQUEST TO EXTEND BRIEFING SCHEDULE AND RESCHEDULE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER Defendant. 21 22 23 24 25 26 27 28 In accordance with Local Rules 6-1(b), 6-2, and 7-12, Plaintiff Jane Doe (“Plaintiff Doe” or “Plaintiff”) and Defendant Roblox Corporation (“Roblox”), by and through their respective counsel, respectfully request that this Court enter an Order (i) granting a brief seven (7) day extension of the deadlines for the parties to respond/reply to Defendant’s motion to dismiss, and if the Court prefers to adjust the motion hearing date and Initial Case Management Conference accordingly, (ii) continuing those events from Wednesday, February 16, 2022 at 2:00 p.m. to a date after February 25, 2022. In support, the parties state as follows: STIP. REQUEST FOR EXTENSION OF TIME -1- CASE NO.: 3:21-CV-03943-WHO 1 1. Defendant Roblox Corporation filed a Motion to Dismiss and Motion to Strike 2 Plaintiff’s complaint (the “Motions”) on December 10, 2021. (Dkt. 25.) The current deadline for 3 Plaintiff to file a response to the Motions is January 14, 2022, and the current deadline for 4 Defendant to file a reply is January 28, 2022. (Id.) 5 2. The parties previously agreed to set the Initial Case Management Conference to 6 coincide with the hearing on Roblox’s Motions. Accordingly, the Court previously (by the 7 parties’ stipulated request) scheduled the hearing on Roblox’s Motions and the Initial Case 8 Management Conference for 2:00 p.m. via videoconference on Wednesday, February 16, 2022. 9 (Dkt. 24.) 10 3. Plaintiff has requested, and Defendant has agreed to, a brief seven (7)-day 11 extension of the deadline to respond to the Motions, due to many individuals on Plaintiff’s legal 12 team and/or their family members testing positive for COVID-19 over the last few weeks, and 13 the attendant consequences (namely, lack of childcare) which have interfered with their business 14 operations. 15 16 4. Accordingly, the parties have agreed to stipulate (subject to the Court’s order) to the following modified briefing schedule for the Motions: 17 • Plaintiff shall file a response to the Motions on or before January 20, 2022; 18 • Roblox shall file any reply in support of its motions on or before February 4, 19 20 2022; 5. The parties’ requested extension does not directly interfere with the February 16, 21 2022 hearing on the Motions (and the Initial Case Management Conference set to follow); 22 however, should the Court wish to continue those events to a later date, the parties request that 23 both the hearing and the Initial Case Management Conference be continued to a date after 24 February 25, 2022, due to scheduling conflicts the prior week. 25 26 27 28 6. There have been two other time modification in this case, as set out in the accompanying Declaration of Lily E. Hough. IT IS SO STIPULATED (subject to Court order). Date: January 11, 2022 STIP. REQUEST FOR ORDER SETTING SCHEDULE By: /s/ Lily E. Hough Rafey Balabanian SBN 315962) -2- CASE NO.: 3:21-CV-03943-WHO 1 rbalabanian@edelson.com Lily Hough (SBN 315277) lhough@edelson.com EDELSON PC 150 California Street, 18th Floor San Francisco, California 94111 Tel: 415.212.9300 Fax: 415.373.9435 2 3 4 5 Mark S. Reich (pro hac vice forthcoming) Courtney E. Maccarone (pro hac vice forthcoming) LEVI & KORSINSKY, LLP 55 Broadway, 10th Floor New York, NY 10006 Telephone: 212-363-7500 Facsimile: 212-363-7171 Email: mreich@zlk.com Email: cmaccarone@zlk.com 6 7 8 9 10 Adam M. Apton (SBN 316506) LEVI & KORSINSKY, LLP 388 Market Street, Suite 1300 San Francisco, CA 94111 Telephone: 415-373-1671 Facsimile: 212-363-7171 Email: aapton@zlk.com 11 12 13 14 15 Attorneys for Plaintiff Jane Doe and the Putative Class 16 21 By: /s/ Anthony J. Weibell Anthony J Weibell (SBN 238850) WILSON SONSINI GOODRICH & ROSATI Professional Corporation 650 Page Mill Road Palo Alto, Ca 94304-1050 Telephone: (650) 493-9300 Facsimile: (650) 565-5100 Email: aweibell@wsgr.com 22 Attorneys For Defendant Roblox Corporation 17 DATED: January 11, 2022 18 19 20 23 24 25 26 27 28 STIP. REQUEST FOR ORDER SETTING SCHEDULE -3- CASE NO.: 3:21-CV-03943-WHO 1 [PROPOSED] ORDER 2 PURSUANT TO STIPULATION, IT IS HEREBY ORDERED: 3 1. 4 5 6 7 8 9 10 Plaintiff shall file any opposition to Roblox’s motion to dismiss on or before January 20, 2022; 2. Roblox shall file its reply in support of its motion to dismiss on or before February 4, 2022; 3. The hearing on Roblox’s motion to dismiss is remains set for February 16, 2022, to be followed by the Initial Case Management Conference; and 4. The parties shall file a Joint Initial Case Management Statement seven (7) days prior to the Initial Case Management Conference. 11 12 13 ENTERED: January 11, 2022 14 15 Honorable William H. Orrick United States District Court 16 17 18 19 20 21 22 23 24 25 26 27 28 STIP. REQUEST FOR ORDER SETTING SCHEDULE -4- CASE NO.: 3:21-CV-03943-WHO 1 2 ATTESTATION OF FILING 3 The undersigned hereby attests that concurrence in the filing of this document has been 4 duly obtained from all other signatories hereto. 5 6 By: /s/ Lily E. Hough 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIP. REQUEST FOR ORDER SETTING SCHEDULE -5- CASE NO.: 3:21-CV-03943-WHO

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