TSI USA LLC v. Uber Technologies Inc

Filing 45


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1 2 3 SHEBAR LAW FIRM Steven M. Shebar (pro hac vice application to be submitted) steveshebar@shebarlaw.com 110 N. Gables Blvd. Wheaton, Illinois 60187 Telephone: 630.877.6833 4 Attorneys for Plaintiff 5 6 7 8 9 10 MORGAN, LEWIS & BOCKIUS LLP Brian C. Rocca, Bar No. 221576 brian.rocca@morganlewis.com Geoffrey T. Holtz, Bar No. 191370 geoffrey.holtz@morganlewis.com Ellie F. Chapman, Bar No. 305473 ellie.chapman@morganlewis.com One Market, Spear Street Tower San Francisco, California 94105-1596 Telephone: 415.442.1000 Facsimile: 415.442.1001 11 Attorneys for Defendant 12 13 UNITED STATES DISTRICT COURT 14 NORTHERN DISTRICT OF CALIFORNIA 15 OAKLAND DIVISION 16 17 TSA USA LLC, Case No. 4:17-cv-03536-HSG Plaintiff, 18 19 v. 20 UBER TECHNOLOGIES, INC., 21 Defendant. Hon. Haywood S. Gilliam, Jr. JOINT STIPULATION AND ORDER ENLARGING TIME FOR FILING OF OPPOSITION AND REPLY BRIEFS IN CONNECTION WITH DEFENDANT’S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT 22 23 Pursuant to Rule 6-1(b) of the Civil Local Rules for the Northern District of California 24 (“Local Rules”), Plaintiff TSI USA, LLC (“TSI”) and Defendant Uber Technologies, Inc. 25 (“Uber”), by their respective undersigned counsel of record, hereby submit their Joint Stipulation 26 Enlarging Time for Filing Of Opposition and Reply Briefs in Connection with Defendant’s 27 Motion to Dismiss the First Amended Complaint (“FAC”). 28 JOINT STIPULATION AND ORDER ENLARGING TIME Case No. 4:17-cv-03536-HSG 1 1. Plaintiff asked Defendant’s consent for an enlargement of time in which to file its 2 opposition to Defendant’s motion to dismiss, due to Plaintiff’s counsel’s undergoing an 3 unforeseen, serious medical issue. Defendant’s counsel consented to the requested extension of 4 four total days (two business days), from September 28 to October 2, 2017, for the filing of 5 Plaintiff’s Opposition. The parties agreed to an equal extension for Defendant’s reply, from 6 October 12 to October 16, 2017. 7 2. The original briefing schedule was the result of a So-Ordered stipulation, entered 8 on August 25, 2017, based on “the parties agreement that efficiency would be served by 9 continuing the Case Management Conference until a date after the proposed hearing on the 10 motion to dismiss, to help logically sequence case events.” Other than this stipulation, there have 11 been no previous time modifications in the case, whether by stipulation or Court order. 12 3. The effect on scheduled matters in the case, other than the parties’ briefing 13 schedule, is shortening from 14 days to 10 days, the time between the filing of the reply and the 14 hearing before this Court on the motion to dismiss, which is set for October 26, 2017 at 2:00 p.m. 15 16 THEREFORE, the parties, through their undersigned counsel, stipulate as follows, and request that the Court enter an order re-setting the remaining briefing schedule as follows: 17 1. Plaintiff shall file its opposition to the motion on or before October 2, 2017. 18 2. Defendant shall file its reply on or before October 16, 2017. 19 3. The hearing date for the motion to dismiss shall remain unchanged. 20 21 IT IS SO STIPULATED. 22 23 Dated: September 29, 2017 By /s/ Brian C. Rocca Brian C. Rocca1 24 MORGAN, LEWIS & BOCKIUS LLP Attorneys for Defendant 25 26 27 1 28 Brian C. Rocca, the filer of this document, hereby attests that he obtained the concurrence of the other signatory, Steven M. Shebar, prior to its filing. 2 JOINT STIPULATION AND ORDER ENLARGING TIME Case No. 4:17-cv-03536-HSG 1 Da ated: Septem mber 29, 201 17 B By /s/ Steven M. Shebar n Steven M. Shebar 2 S SHEBAR LA FIRM AW A Attorneys fo Plaintiff or 3 4 5 6 ORD DER 7 8 PURSUANT TO STIPULAT TION, IT IS SO ORDE S ERED. 9 10 ated: October 2, 2017 Da UNITED STATES DISTRICT JUDGE D 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 JOINT ST TIPULATION AND ORDER N R ENLA ARGING TIME E C Case No. 4:17-cv-03536-HSG G

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