Synchronoss Technologies v. Dropbox Inc

Filing 444

ORDER by Judge Haywood S. Gilliam, Jr. Granting 442 Stipulation Changing Time. (ndrS, COURT STAFF) (Filed on 7/18/2019)

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[COUNSEL OF RECORD IDENTIFIED IN SIGNATURE BLOCK]

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IN THE UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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SYNCHRONOSS TECHNOLOGIES, INC.,

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Plaintiff,
v.

Case No. 4:16-cv-00119-HSG-KAW
STIPULATED REQUEST FOR ORDER
CHANGING TIME AND ORDER
[CIVIL LOCAL RULE 6-2]

DROPBOX, INC.,
Defendant.

Judge: Hon. Haywood S. Gilliam, Jr.

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STIPULATED REQUEST FOR ORDER CHANGING TIME AND ORDER
CASE NO. 4:16-CV-00119-HSG-KAW

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Plaintiff Synchronoss Technologies, Inc., (“Synchronoss”) and Defendant Dropbox, Inc.,

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(“Dropbox”) (collectively, the “Parties”) by and through their respective counsel, and subject to

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the Court’s approval, stipulate as follows:

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WHEREAS, on July 3, 2019, Dropbox filed its Motion for Attorney’s Fees (ECF 436)
and Bill of Costs (ECF 434); and

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WHEREAS, in light of the July 4 holiday and conflicting deadlines facing counsel

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for Synchronoss, there is good cause to extend the deadlines for Synchronoss’ Opposition to

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Dropbox’s Motion for Attorney’s Fees (ECF 436) and Objections to Bill of Costs by two days,

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from July 17, 2019 to and including July 19, 2019, and to extend the deadlines for Dropbox’s

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Reply to Synchronoss’ Opposition to Dropbox’s Motion for Attorney’s Fees (Declaration of

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Sarah S. Eskandari in support of The Parties’ Stipulated Request for Order Changing Time,

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“Eskandari Decl.,” ¶ 3); and

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WHEREAS, on July 16 and 17, 2019, the Parties met and conferred via e-mail to

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discuss the need for approaching the Court to request a brief extension of time for the deadline

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for Synchronoss’ Opposition to Dropbox’s Motion for Attorney’s Fees (ECF 436) and

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Objections to Bill of Costs (ECF 434) by two days, and to extend the deadline for Dropbox’s

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Reply to Synchronoss’ Opposition to Dropbox’s Motion for Attorney’s Fees by two business

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days, to and including July 30, 2019; (Eskandari Decl., ¶ 4); and

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WHEREAS, the Parties respectfully request that the Court extend the deadlines for

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Synchronoss’ Opposition to Dropbox’s Motion for Attorney’s Fees (ECF 436) and Objections

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to Bill of Costs (ECF 434) by two days, from July 17, 2019 to and including July 19, 2019,

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and extend the deadline for Dropbox’s Reply to Synchronoss’ Opposition to Dropbox’s

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Motion for Attorney’s Fees by two business days, to and including July 30, 2019; and

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WHEREAS, there have been nine prior time modifications in this case: (1) when the

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Court granted Synchronoss’ motion for an extension of time to respond to Dropbox’s original

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February 5, 2016 motion to dismiss (ECF 71); (2) when the Court granted the Parties’

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Stipulated Request for an extension of time for Dropbox to file its reply in support of the

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Motion to Dismiss (ECF 90); (3) when the Court granted the Parties’ stipulated request for an
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STIPULATED REQUEST FOR ORDER CHANGING TIME AND ORDER
CASE NO. 4:16-CV-00119-HSG-KAW

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extension of time to submit their ESI Stipulation and Protective Order (ECF 123); (4) when

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the Court granted the Parties’ Stipulated Request to Change the Deadline for Document

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Production (ECF 187); (5) when the Court granted the Parties’ Stipulated Request to

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Complete Currently Noticed Depositions Beyond The Close Of Fact Discovery (ECF 224);

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(6) when the Court granted the Parties’ Stipulated Request to extend the deadlines to complete

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currently noticed fact depositions and to serve expert disclosures and reports (ECF 232);

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(7) when the Court granted the Parties’ Stipulated Request to extend further the deadlines to

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complete currently noticed fact depositions and to serve expert disclosures and reports (ECF

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244); and (8) when the Court granted the Parties’ Stipulated Request to complete currently

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noticed expert depositions beyond the close of expert discovery (ECF 291); and (9) when the

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Court granted the Parties’ Stipulated Request to reschedule the hearing date for dispositive

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and Daubert motions (ECF 342). (Eskandari Decl., ¶ 5.)

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WHEREAS, the Parties’ request will have no impact on the case schedule, as the only

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pending item is the hearing for Dropbox’s Motion for Attorney’s Fees, which is noticed for

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November 14, 2019. (Eskandari Decl., ¶ 6.)

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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, BY AND

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BETWEEN THE PARTIES THROUGH THEIR RESPECTIVE COUNSEL, THAT, the

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Parties respectfully request that the Court: (1) extend the deadlines for Synchronoss’

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Opposition to Dropbox’s Motion for Attorney’s Fees (ECF 436) and Objections to Bill of Costs

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(ECF 434) by two days, from July 17, 2019 to and including July 19, 2019, and (2) extend the

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deadline for Dropbox’s Reply to Synchronoss’ Opposition to Dropbox’s Motion for Attorney’s

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Fees by two business days, to and including July 30, 2019.

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STIPULATED REQUEST FOR ORDER CHANGING TIME AND ORDER
CASE NO. 4:16-CV-00119-HSG-KAW

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Dated this 17th day of July, 2019.

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/s/ Jonathan A. Patchen
STEPHEN E. TAYLOR (SBN 058452)
JONATHAN A. PATCHEN (SBN 237346)
KARAN S. DHADIALLA (SBN 296313)
TAYLOR & PATCHEN, LLP
One Ferry Building, Suite 355
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
E-mail: [e-mail]
E-mail: [e-mail]

/s/ Sarah S. Eskandari
SARAH S. ESKANDARI (SBN 271541)
JENNIFER D. BENNETT (SBN 235196)
DENTONS US LLP
One Market Plaza,
Spear Tower, 24th Floor
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
MARK L. HOGGE (Pro Hac Vice)
KIRK R. RUTHENBERG (Pro Hac Vice)
NICHOLAS H. JACKSON (SBN 269976)
KEVIN GREENLEAF (SBN 256896)
RAJESH NORONHA (Pro Hac Vice)
DENTONS US LLP
1900 K Street, N.W.
Washington, DC 20006
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]

THOMAS H. L. SELBY (pro hac vice)
DAVID M. KRINSKY (pro hac vice)
ADAM D. HARBER (pro hac vice)
CHRISTOPHER J. MANDERNACH (pro
hac vice)
SARAH L. O’CONNOR (pro hac vice)
D. SHAYON GHOSH (SBN 313628)
WILLIAMS & CONNOLLY LLP
725 Twelfth Street, N.W.
Washington, D.C. 20005
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
E-mail: [e-mail]
E-mail: [e-mail]
E-mail: [e-mail]
E-mail: [e-mail]
E-mail: [e-mail]

Attorneys for Plaintiff
Synchronoss Technologies, Inc.

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Attorneys for Defendant
Dropbox, Inc.

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STIPULATED REQUEST FOR ORDER CHANGING TIME AND ORDER
CASE NO. 4:16-CV-00119-HSG-KAW

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ORDER

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THIS MATTER, came before the Court on a Stipulated Request for Order Changing
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Time by Plaintiff Synchronoss Technologies, Inc. and Defendant Dropbox, Inc., (collectively,
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the “Parties”). The Court, having reviewed and considered the submitted papers in this matter
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and all relevant factual statements therein, hereby GRANTS the Parties’ Stipulated Request to
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extend the deadlines for Synchronoss’ Opposition to Dropbox’s Motion for Attorney’s Fees
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(ECF 436) and Objections to Bill of Costs (ECF 434) by two days, from July 17, 2019 to and
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including July 19, 2019, and to extend the deadline for Dropbox’s Reply to Synchronoss’
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Opposition to Dropbox’s Motion for Attorney’s Fees to and including July 30, 2019.
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IT IS SO ORDERED.

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DATED: July 18, 2019

_____________________________________
HONORABLE HAYWOOD S. GILLIAM JR.
UNITED STATES DISTRICT JUDGE

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STIPULATED REQUEST FOR ORDER CHANGING TIME AND ORDER
CASE NO. 4:16-CV-00119-HSG-KAW