CLRB Hanson Industries, LLC et al v. Google Inc.

Filing 19

STIPULATION and [Proposed] Order for Extension of Time to Respond to First Amended Class Action Complaint by Google Inc.. (Jhang, Christopher) (Filed on 11/22/2005)

CLRB Hanson Industries, LLC et al v. Google Inc.

Doc. 19

Case 5:05-cv-03649-JW

Document 19

Filed 11/22/2005

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DAVID T. BIDERMAN, Bar No. 101577 JUDITH B. GITTERMAN, Bar No. 115661 M. CHRISTOPHER JHANG, Bar No. 211463 PERKINS COIE LLP 180 Townsend Street, 3rd Floor San Francisco, California 94107-1909 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Email: [e-mail] Email: [e-mail] Attorneys for Defendant Google, Inc.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

CLRB HANSON INDUSTRIES, LLC d/b/a INDUSTRIAL PRINTING, and HOWARD STERN, on behalf of themselves and all others similarly situated, Plaintiffs,

CASE NO. C O5-03649 JW STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO FIRST AMENDED CLASS ACTION COMPLAINT (Santa Clara Superior Court Case No. 1-05-CV-046409)

15 v. 16 GOOGLE, INC., 17 Defendant. 18 19 20 21 22 23 24 25 26 Action Complaint ("FAC"); 27 28
STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO FIRST AMENDED CLASS ACTION COMPLAINT
[41063-0023-000000/LA053200.010]

WHEREAS, on August 3, 2005, plaintiffs CLRB Hanson Industries, LLC, dba Industrial Printing, and Howard Stern ("plaintiffs") filed their Class Action Complaint ("Complaint") against defendant Google, Inc. ("Google"); WHEREAS, on October 12, 2005, Google filed and served its Motion to Dismiss Plaintiffs' Complaint, noticing a hearing date for this motion on December 5, 2005; WHEREAS, on November 14, 2005, plaintiffs filed and served their First Amended Class

Dockets.Justia.com

Case 5:05-cv-03649-JW

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WHEREAS, Google has requested to extend the deadline for it to respond to plaintiffs'

WHEREAS, plaintiffs have agreed to Google's request; The parties, by and through their attorneys of record, hereby agree and stipulate as follows:

5 6 7 8 9 10 11 12 motion on or before February 2, 2006. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO FIRST AMENDED CLASS ACTION COMPLAINT
[41063-0023-000000/LA053200.010]

(1)

The December 5, 2005 hearing date for Google's Motion to Dismiss Plaintiffs'

Complaint shall be taken off-calendar. (2) If Google files an answer in response to plaintiffs' FAC, Google shall file and serve

such answer on or before December 16, 2005. (3) If Google files a motion in response to plaintiffs' FAC, Google shall file and serve

such motion on or before January 3, 2006, and plaintiffs shall file and serve their opposition to the

/// /// /// /// /// /// /// /// /// /// ///

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(4)

The parties shall meet and confer in December 2005, in accordance with Federal

Rules of Civil Procedure 26(f), and shall file their Joint Case Management Statement on or before January 9, 2006, in compliance with this Court's case management order.

DATED: November 22, 2005

PERKINS COIE LLP By /S/ M. Christopher Jhang Attorneys for Defendant, Google, Inc.

DATED: November 22, 2005

ALEXANDER, HAWES & AUDET, LLP By /S/ Ryan M. Hagan Attorneys for Plaintiffs and the Proposed Class CLRB Hanson Industries, LLC dba Industrial Printing, and Howard Stern

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.

DATED: _____________, 2005.

_______________________________ Honorable James Ware United States District Court Judge

STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO FIRST AMENDED CLASS ACTION COMPLAINT

[41063-0023-000000/LA053200.010]

Case 5:05-cv-03649-JW

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PROOF OF SERVICE I, Susan E. Daniels, declare: I am a citizen of the United States and am employed in the County of San Francisco, State of California. I am over the age of 18 years and am not a party to the within action. My business address is Perkins Coie LLP, 180 Townsend Street, 3rd Floor, San Francisco, California 941071909. I am personally familiar with the business practice of Perkins Coie LLP. On November 22, 2005, I served the following document(s):

STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO FIRST AMENDED CLASS ACTION COMPLAINT
by placing a true copy thereof enclosed in a sealed envelope addressed to the following parties: William M. Audet, Esq. Ryan M. Hagan, Esq. Jason Baker, Esq. ALEXANDER, HAWES & AUDET, LLP 152 North Third Street, Suite 600 San Jose, CA 95112 Tel: [phone]; Fax: [phone] Lester L. Levy, Esq. Michele F. Raphael, Esq. Renee L. Karalian, Esq. WOLF POPPER LLP 845 Third Avenue New York, NY 10022 Tel: [phone]; Fax: [phone] Attorney for Plaintiffs and the Proposed Class

Attorney for Plaintiffs and the Proposed Class

XXX (By Mail) I caused each envelope with postage fully prepaid to be placed for collection and mailing following the ordinary business practices of Perkins Coie LLP. XXX (By Facsimile/Telecopy) I caused each document to be sent by Automatic Facsimile/Telecopier to the number(s) indicated above. I declare under penalty of perjury under the laws of the State of California that the above is true and correct and that this declaration was executed at San Francisco, California.

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STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO FIRST AMENDED CLASS ACTION COMPLAINT
[41063-0023-000000/LA053200.010]

DATED: November 22, 2005.

/S/ Susan E. Daniels