Goodard v. Google, Inc.

Filing 23

STIPULATION -- Stipulated Request To Extend Time In For Plaintiff To Reply In Support Of Her Motion To Remand And To Continue Hearing Date Of September 19, 2008 by Jenna Goodard. (Attachments: # 1 Proposed Order)(Himmelfarb, Alan) (Filed on 9/4/2008)

Goodard v. Google, Inc.

Doc. 23

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KAREN JOHNSON-MCKEWAN (SBN 121570) [e-mail] NANCY E. HARRIS (SBN 197042) [e-mail] NIKKA N. RAPKIN (SBN 244207) [e-mail] ORRICK, HERRINGTON & SUTCLIFFE LLP THE ORRICK BUILDING 405 HOWARD STREET SAN FRANCISCO, CA 94105-2669 TELEPHONE: [phone] FACSIMILE: [phone] ATTORNEYS FOR DEFENDANT

GOOGLE INC.

ALAN HIMMELFARB (SBN 90480) [e-mail] KAMBEREDELSON, LLC 2757 LEONIS BOULEVARD LOS ANGELES, CA 90058 TELEPHONE: [phone] FACSIMILE: [phone] ATTORNEY FOR PLAINTIFF JENNA GODDARD

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

JENNA GODDARD, on her own behalf and Case No. C 08-02738 (JF) on behalf of all others similarly situated, STIPULATED REQUEST TO EXTEND Plaintiff, TIME IN FOR PLAINTIFF TO REPLY IN SUPPORT OF HER MOTION TO v. REMAND AND TO CONTINUE HEARING DATE OF SEPTEMBER 19, GOOGLE, INC., a Delaware corporation, 2008 Defendant.

STIPULATED REQUEST TO EXTEND TIME FOR PLAINTIFF TO REPLY IN SUPPORT OF MOTION TO REMAND AND TO CONTINUE HEARING DATE OF SEPTEMBER 19, 2008

CASE NO. C 08-02738 (JF) ,

Dockets.Justia.com

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The Parties in this action hereby stipulate and agree to the entry of an Order extending the time, up to and including, September 26, 2008, in which Plaintiff may reply in support of her motion to remand this action and to continue the hearing date previously scheduled for September 19, 2008, at 10:30 a.m., and in support of the requested relief state: 1. On April 30, 2008, Plaintiff filed a multi-count class action complaint against the

Defendant in the Superior Court of California, County of Santa Clara, captioned Jenna Goddard v. Google, Inc., Santa Clara Superior Court, Case no. 08-CV-111658. 2. On May 30, 2008, Defendant removed this action to this Honorable Court. On

June 30, 2008, Plaintiff filed a motion to remand this action back to the Superior Court of Santa Clara. Thereafter, the parties stipulated to an extension of time for Defendant to respond to Plaintiff's motion to remand through August 29, 2008. 3. By Order dated July 7, 2008, the Court granted Defendant an extension of time to

August 29, 2008, in which to respond to Plaintiff's motion to remand; set September 5, 2008, as the deadline for Plaintiff to reply in support of her motion; and set the motion down for hearing on September 19, 2008, at 10:30 a.m. 4. On August 29, 2008, Defendant timely served Plaintiff's counsel with its response

in opposition to the motion to remand, along with several other related documents filed with the Court on that day. 5. In light of the information raised in Defendant's response brief, Plaintiff seeks an

extension of time to evaluate such information and to draft an appropriate reply. 6. As a result, on September 4, 2008, counsel for the parties conferred by telephone

and agreed--subject to Court approval--to stipulate to an extension of time, up to and including, September 26, 2008, in which Plaintiff may reply in support of her motion to remand, and continue the previously scheduled hearing date of September 19, 2008, to October 3, 2008, or any date thereafter as is convenient for the Court. // //

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STIPULATED REQUEST TO EXTEND TIME FOR PLAINTIFF TO REPLY IN SUPPORT OF MOTION TO REMAND AND TO CONTINUE HEARING DATE OF SEPTEMBER 19, 2008 CASE NO. C 08-02738 (JF)

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WHEREFORE, the Parties respectfully request this Court enter an Order (a) extending the time, up to and including, September 26, 2008, in which Plaintiff may reply in support of her motion to remand; (b) continue the previously scheduled hearing of September 19, 2008, to October 3, 2008, at 10:30 a.m., or any date thereafter as is convenient for the Court. IT IS SO STIPULATED.

Dated: September 4, 2008

KAMBEREDELSON, LLC /s/ Alan Himmelfarb

ALAN HIMMELFARB (SBN 90480) [e-mail] KAMBEREDELSON, LLC 2757 LEONIS BOULEVARD LOS ANGELES, CA 90058 TELEPHONE: [phone] FACSIMILE: [phone] ATTORNEY FOR PLAINTIFF JENNA GODDARD

Dated: September 4, 2008

ORRICK, HERRINGTON & SUTCLIFFE LLP

NIKKA N. RAPKIN (SBN # 244207) [e-mail] ORRICK, HERRINGTON & SUTCLIFFE LLP THE ORRICK BUILDING 405 HOWARD STREET SAN FRANCISCO, CA 94105-2669 TELEPHONE: [phone] FACSIMILE: [phone] ATTORNEY FOR DEFENDANT

/s/ Nikka N. Rapkin

GOOGLE INC.

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STIPULATED REQUEST TO EXTEND TIME FOR PLAINTIFF TO REPLY IN SUPPORT OF MOTION TO REMAND AND TO CONTINUE HEARING DATE OF SEPTEMBER 19, 2008 CASE NO. C 08-02738 (JF)