Ziolkowski v. Netflix, Inc. et al

Filing 52

ORDER by Judge Haywood S. Gilliam, Jr. Granting 51 Stipulation to Continue the Initial Case Management Conference. (ndrS, COURT STAFF) (Filed on 4/6/2018)

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KEITH E. EGGLETON, State Bar No. 159842
Email: [e-mail]
RODNEY G. STRICKLAND, State Bar No. 161934
Email: [e-mail]
CHERYL W. FOUNG, State Bar No. 108868
Email: [e-mail]
LUKE A. LISS, State Bar No. 247520
Email: [e-mail]
WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
650 Page Mill Road
Palo Alto, CA 94304-1050
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendants
Netflix, Inc., Reed Hastings,
and David Wells

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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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JAMES ZIOLKOWSKI, Individually and On
Behalf of All Other Persons Similarly Situated,

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Plaintiff,
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v.
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NETFLIX, INC., REED HASTINGS, and
DAVID WELLS,

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Defendants.

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STIPULATED REQUEST AND ORDER TO CONTINUE
INITIAL CMC
CASE NO.: 4:17-CV-01070-HSG

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CASE NO.: 4:17-CV-01070-HSG
CLASS ACTION
STIPULATED REQUEST AND
ORDER TO CONTINUE THE
INITIAL CASE MANAGEMENT
CONFERENCE

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Defendants Netflix, Inc., Reed Hastings, and David Wells (collectively, “Defendants”),

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by and through their counsel, and Lead Plaintiff Michael J. DuDash, individually and behalf of

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all others similarly situated (“Plaintiff”), by and through his counsel, hereby stipulate to the

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following:

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WHEREAS, pursuant to the Court’s Order of June 14, 2017, appointing Lead Plaintiff

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and Lead Counsel, and setting a schedule for the filing of an amended complaint and motion to

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dismiss briefing thereon (the “Schedule”);

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WHEREAS, pursuant to the Schedule, Plaintiff’s amended complaint was filed on
August 14, 2017, and briefing on Defendants’ motion to dismiss the amended complaint has
since been completed;
Whereas, the motion to dismiss Plaintiff’s amended complaint is under submission as of

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the date of this stipulation, and the stay of discovery under the PSLRA, 15 U.S.C. § 78u-

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4(b)(3)(B), remains in place while such motion is pending;

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WHEREAS, further pursuant to the Schedule entered on June 14, 2017, a case
management conference is currently set for April 17, 2018;
WHEREAS, in order to avoid the unnecessary expenditure of judicial resources or effort

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by the parties and the Court prior to the Court’s decision on Defendant’s motion to dismiss, the

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parties have agreed, subject to the Court’s approval, to the continuance of the case management

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conference; and

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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, and respectfully

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requested, by and among the parties hereto, through their undersigned counsel of record, that the

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Court order as follows:

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The deadline for submission of a case management statement is extended and the

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case management conference is continued until such time following the Court’s Order on

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Defendant’s motion to dismiss, on a date to be selected by the Court.

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STIPULATED REQUEST AND ORDER TO CONTINUE
INITIAL CMC
CASE NO.: 4:17-CV-01070-HSG

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IT IS SO STIPULATED.

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Dated: April 6, 2018

WILSON SONSINI GOODRICH & ROSATI
Professional Corporation

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By: s/ Luke A. Liss
Luke A. Liss

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Attorneys for Defendants
Netflix, Inc., Reed Hastings,
and David Wells

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Dated: April 6, 2018

KAHN, SWICK & FOTI, LLP

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By: s/Ramzi Abadou
Ramzi Abadou

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KAHN SWICK & FOTI, LLP
912 Cole Street #251
San Francisco, CA 94117
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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FINKELSTEIN & KRINSK LLP
Jeffrey R. Krinsk, Esq.
Trenton R. Kashima, Esq.
550 West C Street, Suite 1760
San Diego, California 92101-3579
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff

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ATTESTATION (CIVIL LOCAL RULE 5-1(i)(3))
In accordance with Civil Local Rule 5-1(i)(3), I attest that Ramzi Abadou concurred in
the filing of this document.
Dated: April 6, 2018

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s/ Luke A. Liss
Luke A. Liss

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STIPULATED REQUEST AND ORDER TO CONTINUE
INITIAL CMC
CASE NO.: 4:17-CV-01070-HSG

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Order
PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: April 6, 2018

______________________________________
Honorable Haywood S. Gilliam, Jr.
United States District Judge

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STIPULATED REQUEST AND ORDER TO CONTINUE
INITIAL CMC
CASE NO.: 4:17-CV-01070-HSG

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