In re Google Referrer Header Privacy Litigation

Filing 40

STIPULATION WITH PROPOSED ORDER / Stipulation to Extend Time For Filing Motion To Dismiss and Stipulated Request For Order Changing Time For Motion To Dismiss Briefing filed by Google Inc.. (Attachments: #1 Declaration of Randall W. Edwards in Support of Stipulation, #2 Proposed Order)(Edwards, Randall) (Filed on 5/8/2012)

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RANDALL W. EDWARDS (S.B. #179053)
[e-mail]
JEAN NIEHAUS (S.B. #254891)
[e-mail]
O'MELVENY & MYERS LLP
Two Embarcadero Center, 28th Floor
San Francisco, California 94111-3823
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant
Google Inc.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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PALOMA GAOS, et al.

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Plaintiffs,

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STIPULATION TO EXTEND TIME
FOR FILING MOTION TO DISMISS
AND STIPULATED REQUEST FOR
ORDER CHANGING TIME FOR
MOTION TO DISMISS BRIEFING

Defendant.

Honorable Edward J. Davila

v.
GOOGLE INC.,

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Case No. 5:10-cv-04809-EJD

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STIPULATED EXTENSION & REQUEST
5:10-CV-04809-EJD

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Whereas Plaintiffs Paloma Gaos and Anthony Italiano (“Plaintiffs”) filed the Second
Amended Complaint (“SAC”) in the above-captioned action on May 1, 2012;

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Whereas under the Federal Rules of Civil Procedure Defendant Google Inc. (“Google”)
must answer or otherwise respond to the SAC no later than May 15, 2012;

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Whereas counsel for Google has communicated its intention to file a motion to dismiss to
counsel for Plaintiffs, and the parties have stipulated both to extend Google’s deadline to respond
to the SAC and to a schedule for the remaining motion to dismiss briefing;

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Whereas the parties have agreed upon and reserved September 21, 2012 for the Court to
hear this motion;

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Whereas the parties have agreed to this extension to give themselves adequate time to
brief the issues presented in this case;

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Now, therefore, Pursuant to Civil Local Rule 6-1(a), the parties hereby stipulate to the

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following:
Google’s motion to dismiss the SAC will be due no later than May 30, 2012.

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Now, therefore, Pursuant to Civil Local Rules 6-1(b) and 6-2, and as supported by the
Declaration of Randall W. Edwards, the parties make the following stipulated request:

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Plaintiffs’ opposition to Google’s motion to dismiss will be due no later than July 3, 2012;

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Google’s reply in further support of its motion to dismiss will be due no later than July 17,
2012.

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This stipulated extension and briefing schedule will not affect the date of any event or
deadline already fixed by the Court in this case.

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STIPULATED EXTENSION & REQUEST
5:10-CV-04809-EJD

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Dated: May 8, 2012

O’MELVENY & MYERS LLP

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By: /s/ Randall W. Edwards
Randall W. Edwards
Attorneys for Defendant
Google Inc.

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Dated: May 8, 2012

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ASCHENBRENER LAW, P.C.
NASSIRI & JUNG LLP

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By: /s/ Michael J. Aschenbrener
Michael J. Aschenbrener
Attorneys for Plaintiff
Paloma Gaos

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Filer’s Attestation: In compliance with General Order 45(X)(B), I hereby attest that concurrence

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in the filing of this Stipulation has been obtained from Michael Aschenbrener.

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Dated: May 8, 2012

O’MELVENY & MYERS LLP

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By: /s/ Randall W. Edwards
Randall W. Edwards
Attorneys for Defendant
Google Inc.

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STIPULATED EXTENSION & REQUEST
5:10-CV-04809-EJD