Valdez-Marquez et al v. Netflix Inc

Filing 11

STIPULATION AND ORDER Extending Time to Respond to the Complaint re 10 Stipulation. Defendant shall respond to the complaint no later than 3/10/2010. Signed by Judge James Ware on 2/1/2010. (ecg, COURT STAFF) (Filed on 2/1/2010)

KEITH E. EGGLETON, State Bar No. 159842 Email: [e-mail] RODNEY G. STRICKLAND, State Bar No. 161934 Email: rstricklandmwser.com DALE BISH, ~tate%arko.235390 Email: [e-mail] WILSON SONSINI GOODRICH & ROSATI Professional Corporation 650 Page Mill Road Palo Alto, CA 94304-1050 Telephone: [phone] Attorneys for Defendant NETFLIX, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

JANE DOE, individually; NELLY VALDEZ) MAROUEZ. ANTHONY SINOPOLI. PAUL NAVLRRO; individually and on behalf of a class j ) of similarly situated individuals, Plaintiffs,
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CASE NO.: C09-05903-JW-PVT STIPULATION AND [PROPOSED] ORDER REGARDING DEFENDANT'S RESPONSE TO THE COMPLAINT

NETFLIX, INC., a Delaware Corporation, and DOES 1 THROUGH 50, inclusive, Defendants.

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WHEREAS, Plaintiffs filed and served a class action complaint alleging certain claims against defendant Netflix, Inc. ("Defendant") for alleged violations of certain privacy and consumer protection statutes; WHEREAS, Defendant has received one 30-day extension of time to respond to the complaint; WHEREAS, Defendant has requested and Plaintiffs have agreed to an additional 30-day extension of time for Defendant to respond to the complaint; and

STIPULATION DEFENDANT'S RESPONSE TO RE THE COMPLAINT
CASENO. C09-05903-JW-PVT

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WHEREAS, this proposed extension would have no effect on the current schedule for the case; NOW THEREFORE, IT IS HEREBY STIPULATED that: 1. 2. Defendant shall respond to the complaint no later than March 10,2010 This stipulation is without prejudice to the rights, claims, or defenses of any party,

and shall not be used by Defendant as evidence of, or to support any argument that, Plaintiffs have not timely pursued their claims or have not been diligent.

Dated: January 27, 2010 S/ Rodney G. Strickland. Jr. Keith E. Eggleton Rodney G. Strickland, Jr. WILSON SONSINI GOODRICH & ROSATI Attorneys for Defendant NETFLIX, INC.

Dated: January 27,2010 S/ David C. Parisi Scott A. Kamber David A. Stampley KamberEdelson, LLC Joseph H. Malley Law Office of Joseph H. Malley David C. Parisi (SBN 162248) Suzanne Havens Beckman (SBN 188814) Parisi & Havens LLP Attorneys for Plaintiffs

STrPULATION RE DEFENDANT'S RESPONSE TO THE COMPLAINT

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CASENO. C09-05903-JW-PVT

[PROPOSED] ORDER

Defendant shall respond to the complaint no later than March 10,2010.

PURSUANT TO STIPULATION, IT IS SO ORDERED.
3ated:

February 1 ,2010 THE HONORABLE JAMES WARE

STIPULATION RE DEFENDANT'S RESPONSE TO THE COMPLAINT

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ZASENO. C09-05903-JW-PVT

I, Rodney G. Strickland, Jr., am the ECF User whose identification and password are being used to file the Stipulation Regarding Defendant's Response to the Complaint. I hereby attest David C. Parisi has concurred in this filing.

Dated: January 27, 2010 sl Rodnev G. Strickland. Jr. Rodney G. Strickland, Jr. WILSON SONSINI GOODRICH & ROSATI Attorneys for Defendant NETFLIX, INC.

STIPULATION DEFENDANT'S RE RESPONSE TO
THE COMPLAINT

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CASENO. C09-05903-JW-PVT