Synchronoss Technologies, Inc. v. Funambol, Inc.

Filing 94

ORDER by Judge Haywood S. Gilliam, Jr. Granting 93 Stipulation To Further Change Time. (ndrS, COURT STAFF) (Filed on 4/6/2017)

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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FURTHER STIPULATED REQUEST
FOR ORDER CHANGING TIME AND
ORDER

v.
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FUNAMBOL, INC.,
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[CIVIL LOCAL RULE 6-2]
Defendant.

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Honorable Haywood S. Gilliam, Jr.

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FURTHER 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) and, on April 4, 2017, extended the deadline to April 4, 2017. (ECF 92.)
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WHEREAS, in light of the fact that, to date, the Parties have been working diligently to

8 narrow the issues of dispute with respect to the ESI Stipulation and Protective Order to reduce
9 the burden upon the Court and continue to negotiate the terms of the ESI Stipulation and
10 Protective Order, and given the complexity of the case, have not yet come to an agreement on
11 the terms of such a stipulation and Protective Order, there is good cause to extend the date for
12 the Parties to submit their ESI Order and Protective Order by three additional court days, from
13 April 4, 2017, to and including April 7, 2017.
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WHEREAS, there have only been four prior time modifications in this case with respect

15 to the Case Management Conference: (1) pending the Court’s decision on the administrative
16 motion to relate the case to Funambol and Egnyte; (2) pending the Court’s decision on
17 Funambol’s Motion to Dismiss in the related matter Synchronoss v. Dropbox, Case No. 16-cv18 00119-HSG (ECF 52, 57); (3) when the Court granted the Parties’ Stipulated Request to
19 continue the date of the Case Management Conference (ECF 78); and (4) when the Court
20 granted the Parties Stipulated Request to extend the deadline to submit their ESI Stipulation and
21 Protective Order (ECF 92). See Civil L.R. 6-2(a)(2).
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WHEREAS, the Parties’ requested extension will have no impact on the schedule for the

23 case overall, as the remaining deadlines in the Scheduling Order will be unaffected; the
24 requested extension will leave the Parties with two (2) full weeks prior to the April 24, 2017
25 due date for Synchronoss’ Disclosure of Asserted Claims and Infringement Contentions and
26 accompanying document production, per Patent Local Rules 3-1 and 3-2 and the Order Setting
27 Schedule (ECF 133); and the brief extension will not prejudice any Party.
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2.
FURTHER 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

2 BETWEEN THE PARTIES THROUGH THEIR RESPECTIVE COUNSEL, THAT subject to the
3 Court’s approval: The date for the Parties to file their ESI Stipulation and Protective Order is
4 extended to and including April 7, 2017.
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6 Dated: April 4, 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: April 4, 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.
FURTHER 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 6, 2017
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__________________________________
UNITED STATES DISTRICT JUDGE
HONORABLE HAYWOOD S. GILLIAM, JR.

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4.
FURTHER 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: April 4, 2017

By

/s/ Sarah S. Eskandari
SARAH S. ESKANDARI

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5.
FURTHER STIPULATED REQUEST FOR ORDER CHANGING TIME AND [PROPOSED] ORDER
CASE NO. 4:16-CV-02026-HSG