"In Re: Facebook Privacy Litigation"

Filing 110

STIPULATION AND [PROPOSED] ORDER REGARDING BRIEFING SCHEDULE FOR MOTION TO ALTER OR AMEND JUDGMENT (CIVIL LOCAL RULE 6-1(B)) by Facebook, Inc.. (Brown, Matthew) (Filed on 12/23/2011)

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COOLEY LLP
MICHAEL G. RHODES (116127)
([e-mail])
MATTHEW D. BROWN (196972)
([e-mail])
BENJAMIN H. KLEINE (257225)
([e-mail])
KELLY A. COOKE (258003)
([e-mail])
MEGAN L. DONOHUE (266147)
([e-mail])
101 California Street, 5th Floor
San Francisco, CA 94111-5800
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant
FACEBOOK, INC.

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ASCHENBRENER LAW, P.C.
MICHAEL J. ASCHENBRENER (277114)
([e-mail])
795 Folsom Street, First Floor
San Francisco, CA 94107
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Plaintiffs
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(Additional counsel for Plaintiffs listed on signature page)
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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IN RE: FACEBOOK PRIVACY
LITIGATION

Case No. 10-cv-02389-JW

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STIPULATION AND [PROPOSED] ORDER
REGARDING BRIEFING SCHEDULE FOR
MOTION TO ALTER OR AMEND
JUDGMENT (CIVIL LOCAL RULE 6-1(B))

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ACTION FILED: May 28, 2010

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COOLEY LLP
ATTO RNEY S AT LAW
SAN FRA NCI S CO

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STIPULATION AND [PROPOSED] ORDER
REGARDING BRIEFING SCHEDULE
NO. 10-CV-02389-JW

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This Stipulation is entered into by and among plaintiffs David Gould and Mike Robertson

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(collectively, “Plaintiffs”) and defendant Facebook, Inc. (“Facebook”) (Plaintiffs and Facebook

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collectively, “the Parties”), by and through their respective counsel.

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WHEREAS on November 22, 2011 this Court dismissed Plaintiffs’ First Amended
Consolidated Complaint without leave to amend;
WHEREAS on December 20, 2011, Plaintiffs filed a Motion to Alter or Amend
Judgment, Or, Alternatively, For Relief From Judgment (“Motion”);
WHEREAS currently Facebook’s Opposition to the Motion is due January 3, 2012, and
Plaintiffs’ Reply in support of the Motion is due January 10, 2012;

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WHEREAS, Facebook’s offices are closed for the holiday season from Friday, December

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23 through Tuesday, December 27, and from Friday, December 30 through Monday, January 2

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(and many employees will take off all or most of the period from Friday, December 23 through

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Monday, January 2);

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WHEREAS under Civil Local Rule 6-1(b), the Parties may, by written stipulation, request

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a Court order extending the time for Facebook’s Opposition to and Plaintiffs’ Reply in support of

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the Motion; AND

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WHEREAS extending the briefing deadlines and hearing date as set forth below will not

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alter the date of any other event or deadline already fixed by Court order or affect any scheduling

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for the case.

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NOW, THEREFORE, the Parties hereby stipulate and agree, subject to approval by the

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Court, as follows:

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1.

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The deadline for Facebook’s Opposition to Plaintiffs’ Motion is extended to and

including January 20, 2012;
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The deadline for Plaintiffs’ Reply in support of its Motion is extended to and

including February 3, 2012; AND
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The hearing on the Motion is continued from January 30, 2012, at 9:00 a.m., to

February 27, 2012, at 9:00 a.m.
IT IS SO STIPULATED.

COOLEY LLP
ATTO RNEY S AT LAW
SAN FRA NCI S CO

2.

STIPULATION AND [PROPOSED] ORDER
REGARDING BRIEFING SCHEDULE
NO. 10-CV-02389-JW

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Dated: December 23, 2011

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COOLEY LLP
/s/ Matthew D. Brown
Matthew D. Brown (196972)
Attorneys for Defendant FACEBOOK, INC.

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Dated: December 23, 2011

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ASCHENBRENER LAW, P.C.
/s/ Michael J. Aschenbrener
Michael J. Aschenbrener (277114)
Attorneys for Plaintiffs

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Dated: December 23, 2011

NASSIRI & JUNG LLP
/s/ Kassra P. Nassiri
Kassra P. Nassiri (215405)
Attorneys for Plaintiffs

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NASSIRI & JUNG LLP
KASSRA P. NASSIRI (215405)
([e-mail])
CHARLES H. JUNG (217909)
([e-mail])
47 Kearney Street, Suite 700
San Francisco, CA 94108
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Plaintiffs

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IT IS SO ORDERED.

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DATED:_December ____, 2011
HON. JAMES WARE
UNITED STATES DISTRICT JUDGE

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COOLEY LLP
ATTO RNEY S AT LAW
SAN FRA NCI S CO

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STIPULATION AND [PROPOSED] ORDER
REGARDING BRIEFING SCHEDULE
NO. 10-CV-02389-JW

FILER’S ATTESTATION

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Pursuant to General Order No. 45, Section X, Subparagraph B, the undersigned attests that

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all signatories have concurred in the filing of this Stipulation and [Proposed] Order Regarding

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Briefing Schedule for Motion to Alter or Amend Judgment.

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Dated: December 23, 2011

COOLEY LLP

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/s/ Matthew D. Brown
Matthew D. Brown (196972)

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735363 v1/SD

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COOLEY LLP
ATTO RNEY S AT LAW
SAN FRA NCI S CO

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STIPULATION AND [PROPOSED] ORDER
REGARDING BRIEFING SCHEDULE
NO. 10-CV-02389-JW