Kinderstart.Com, LLC v. Google, Inc.

Filing 24

Case 5:06-cv-02057-JF

Document 24

Filed 06/06/2006

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DAVID H. KRAMER, State Bar No. 168452 LISA A. DAVIS, State Bar No. 179854 BART E. VOLKMER, State Bar No. 223732 WILSON SONSINI GOODRICH & ROSATI Professional Corporation 650 Page Mill Road Palo Alto, CA 94304-1050 Telephone: [phone] Facsimile: [phone] [e-mail] JONATHAN M. JACOBSON WILSON SONSINI GOODRICH & ROSATI Professional Corporation 12 East 49th Street, 30th Floor New York, NY 10017-8203 Telephone: [phone] Facsimile: [phone] [e-mail] Attorneys for Defendant Google Inc. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

KINDERSTART.COM, LLC, a California limited liability company, on behalf of itself and all others similarly situated, Plaintiffs, v. GOOGLE INC., a Delaware corporation, Defendant.

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CASE NO.: C 06-2057 JF (RS) JOINT STIPULATION AND [PROPOSED] ORDER SETTING BRIEFING SCHEDULE ON PLAINTIFF'S MOTION FOR A PRELIMINARY INJUNCTION Before: Hon. Jeremy Fogel Date: June 30, 2006 Time: 9:00 a.m. Courtroom: 3

JOINT STIPULATION RE BRIEFING SCHEDULE PRELIMINARY INJUNCTION Case No. 06-2057 JF (RS)

ON

Case 5:06-cv-02057-JF

Document 24

Filed 06/06/2006

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WHEREAS, on May 26, 2006, Plaintiff KinderStart.com LLC ("KinderStart") filed a Motion for Preliminary Injunction ("Injunction Motion") and noticed it for a hearing on June 30, 2006; WHEREAS, on May 31, 2006, Defendant Google Inc. ("Google") filed a Miscellaneous Administrative Request Under Civil L.R. 7-11 ("Google's Pending 7-11 Request") to Continue or Vacate the Hearing Date on KinderStart's Motion for Preliminary Injunction (to which KinderStart filed an opposition on June 1, 2006); WHEREAS, on June 1, 2006, KinderStart filed a Motion for Leave to File Excess Pages on its Motion for Preliminary Injunction (to which Google filed an opposition on June 2, 2006); Pursuant to Civil L.R. 6-2 and 7-12, KinderStart and Google jointly submit this stipulation to request the Court to enter a modified briefing schedule on KinderStart's Preliminary Injunction motion as follows: June 16, 2006 ­ Google's Opposition to KinderStart's Motion for Preliminary Injunction June 23, 2006 ­ KinderStart's Reply in Support of its Motion for Preliminary Injunction June 30, 2006 ­ Hearing on KinderStart's Motion for Preliminary Injunction provided, however, that this stipulation shall be subject to the Court's decision on Google's Pending 7-11 Request (that could result in the vacating and/or rescheduling of the hearing date on the Injunction Motion). The parties are not otherwise hereby modifying or waiving the arguments contained in their respective motions, requests, or related oppositions thereto referred to in the above recital clauses.

Dated: June 6, 2006

WILSON SONSINI GOODRICH & ROSATI Professional Corporation By: /s/ David H. Kramer

Attorneys for Defendant Google Inc.

JOINT STIPULATION RE BRIEFING SCHEDULE PRELIMINARY INJUNCTION Case No. 06-2057 JF (RS)

ON

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Case 5:06-cv-02057-JF

Document 24

Filed 06/06/2006

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Dated: June 6, 2006

GLOBAL LAW GROUP

By:

/s/ Gregory J. Yu

Attorneys for Plaintiff KinderStart.com LLC and for the Members of the Class

ECF CERTIFICATION I, David H. Kramer, am the ECF User whose identification and password are being used to file this Joint Case Stipulation & Proposed Order. In compliance with General Order 45.X.B, I hereby attest that Gregory J. Yu has concurred in this filing. Dated: June 6, 2006 WILSON SONSINI GOODRICH & ROSATI Professional Corporation By: /s/ David H. Kramer

Attorneys for Defendant Google Inc. [PROPOSED] ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED. The briefing schedule set forth above is hereby approved by the Court.

Dated: ________________

___________________________________ The Honorable Jeremy Fogel United States District Judge

JOINT STIPULATION RE BRIEFING SCHEDULE PRELIMINARY INJUNCTION Case No. 06-2057 JF (RS)

ON

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