Synchronoss Technologies, Inc. v. Funambol, Inc.

Filing 92

ORDER by Judge Haywood S. Gilliam, Jr. Granting 91 Stipulation To Change Time. (ndrS, COURT STAFF) (Filed on 4/4/2017)

1 MARK L. HOGGE (pro hac vice)
SHAILENDRA K. MAHESHWARI (pro hac vice)
2 NICHOLAS H. JACKSON (SBN 269976)
DENTONS US LLP
3 1900 K Street, N.W.
Washington, DC 20006
4 Telephone: [phone]
Facsimile: [phone]
5 Email: [e-mail]
Email: [e-mail]
6 Email: [e-mail]
7 SARAH S. ESKANDARI (SBN 271541)
DENTONS US LLP
8 One Market Plaza
Spear Tower, 24th Floor
9 San Francisco, California 94105
Telephone: [phone]
10 Facsimile: [phone]
Email: [e-mail]
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Attorneys for Plaintiff
12 SYNCHRONOSS TECHNOLOGIES, INC.

DURIE TANGRI LLP
SONALI D. MAITRA(SBN 254896)
[e-mail]
TIMOTHY C. SAULSBURY(SBN 281434)
[e-mail]
CATHERINE Y. KIM (SBN 308442)
[e-mail]
217 Leidesdorff Street
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
FUNAMBOL, INC.

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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.,

Case No.: 4:16-cv-02026-HSG

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Plaintiff,
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v.

STIPULATED REQUEST FOR ORDER
CHANGING TIME AND ORDER

FUNAMBOL, INC.,

[CIVIL LOCAL RULE 6-2]

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Defendant.

Honorable Haywood S. Gilliam, Jr.

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STIPULATED REQUEST FOR ORDER CHANGING TIME AND [PROPOSED] ORDER
CASE NO. 4:16-CV-02026-HSG

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

2 (“Synchronoss”), collectively (the “Parties”), by and through their respective counsel and
3 subject to the Court’s approval, have met and conferred and stipulate as follows:
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WHEREAS, on March 15, 2017, the Court issued an Order Setting Schedule that set a

5 March 31, 2017 deadline for the Parties to submit an ESI Stipulation and Protective Order (ECF
6 133).
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WHEREAS, in light of the fact that, to date, the Parties continue to negotiate the ESI

8 Stipulation and Protective Order, and given the complexity of the case, have not yet come to an
9 agreement on the terms of such a stipulation and Protective Order, there is good cause to extend
10 the date for the Parties to submit their ESI Order and Protective Order by two court days, from
11 March 31, 2017, to and including April 4, 2017.
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WHEREAS, there have only been three prior time modifications in this case with

13 respect to the Case Management Conference: (1) pending the Court’s decision on the
14 administrative motion to relate the case to Funambol and Egnyte; (2) pending the Court’s
15 decision on Funambol’s Motion to Dismiss in the related matter Synchronoss v. Dropbox, Case
16 No. 16-cv-00119-HSG (ECF 52, 57) and; (3) when the Court granted the Parties’ Stipulated
17 Request to continue the date of the Case Management Conference (ECF 78). See Civil L.R. 618 2(a)(2).
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WHEREAS, the Parties’ requested extension will have no impact on the schedule for the

20 case overall, as the remaining deadlines in the Scheduling Order will be unaffected; the
21 requested two day extension will leave the Parties with three (3) weeks prior to the April 24,
22 2017 due date for Synchronoss’ Disclosure of Asserted Claims and Infringement Contentions
23 and accompanying document production, per Patent Local Rules 3-1 and 3-2 and the Order
24 Setting Schedule (ECF 133); and the brief extension will not prejudice any Party.
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2.
STIPULATED REQUEST FOR ORDER CHANGING TIME AND [PROPOSED] ORDER
CASE NO. 4:16-CV-02026-HSG

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

4 BETWEEN THE PARTIES THROUGH THEIR RESPECTIVE COUNSEL, THAT subject to the
5 Court’s approval: The date for the Parties to file their ESI Stipulation and Protective Order is
6 extended from March 31, 2017, to and including April 4, 2017.
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8 Dated: March 31, 2017

DENTONS US LLP

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By:
/s/ Sarah S. Eskandari
SARAH S. ESKANDARI
MARK L. HOGGE
SHAILENDRA K. MAHESHWARI
NICHOLAS H. JACKSON

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Attorneys for Plaintiff
Synchronoss Technologies, Inc.

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Dated: March 31, 2017

DURIE TANGRI LLP

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By:
/s/ Timothy C. Saulsbury
SONALI D. MAITRA
TIMOTHY C. SAULSBURY
CATHERINE Y. KIM

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Attorneys for Defendant
Funambol, Inc.

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3.
STIPULATED REQUEST FOR ORDER CHANGING TIME AND [PROPOSED] ORDER
CASE NO. 4:16-CV-02026-HSG

ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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5 Dated: April 4, 2017
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__________________________________
UNITED STATES DISTRICT JUDGE
HONORABLE HAYWOOD S. GILLIAM, JR.

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STIPULATED REQUEST FOR ORDER CHANGING TIME AND [PROPOSED] ORDER
CASE NO. 4:16-CV-02026-HSG

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FILER’S ATTESTATION:
I, Sarah S. Eskandari, am the ECF user whose ID and password are being used to file

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the above STIPULATED REQUEST FOR ORDER CHANGING TIME AND

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[PROPOSED] ORDER [CIVIL LOCAL RULE 6-2]. In compliance with Civil Local Rule

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5-1(i)(3), I hereby attest that each listed counsel above has concurred in this filing.

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Dated: March 31, 2017

By

/s/ Sarah S. Eskandari
SARAH S. ESKANDARI

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STIPULATED REQUEST FOR ORDER CHANGING TIME AND [PROPOSED] ORDER
CASE NO. 4:16-CV-02026-HSG