In re Google Referrer Header Privacy Litigation

Filing 42

STIPULATION WITH PROPOSED ORDER / Stipulated Request For Order Changing Time For Motion To Dismiss Briefing filed by Google Inc.. (Attachments: #1 Declaration Of Randall W. Edwards In Support, #2 Proposed Order)(Edwards, Randall) (Filed on 5/30/2012)

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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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v.

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GOOGLE INC.,

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Case No. 5:10-cv-04809-EJD
STIPULATED REQUEST FOR
ORDER CHANGING TIME FOR
MOTION TO DISMISS BRIEFING
Honorable Edward J. Davila

Defendant.

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STIPULATED REQUEST
5:10-CV-04809-EJD

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Google Inc. submits this stipulated request to adjust the briefing schedule on the motion to
dismiss in a manner that will not affect the previously established hearing date, which is
scheduled for September 21, 2012.

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Whereas Plaintiffs Paloma Gaos and Anthony Italiano 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 Google was required to answer or
otherwise respond to the SAC no later than May 15, 2012;

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Whereas counsel for Google has previously communicated its intention to file a motion to
dismiss to counsel for Plaintiffs, and it obtained September 21, 2012 for a hearing date on that
motion.

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Whereas the parties stipulated both to a schedule for the motion to dismiss briefing to
provide the parties adequate time to brief the issues presented in this case;

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Whereas on May 9, 2012, the Court granted the parties’ previous stipulation and stipulated
request for extension under which Google’s motion to dismiss the SAC was due May 30, 2012,
Plaintiffs’ opposition was due July 3, 2012, and Google’s reply was due July 17, 2012;

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Whereas the parties have agreed that short extension of the briefing schedule is
appropriate to provide time to discuss certain issues in advance, and the extension would not
affect the previously set hearing date and would still allow approximately seven weeks between
the reply brief and the hearing date;

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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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Google’s motion to dismiss the SAC will be due no later than June 15, 2012;

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Plaintiffs’ opposition to Google’s motion to dismiss will be due no later than July 19,
2012;
Google’s reply in further support of its motion to dismiss will be due no later than August
2, 2012.

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This stipulated extension and briefing schedule will not affect the date of any event or
STIPULATED REQUEST
5:10-CV-04809-EJD

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deadline already fixed by the Court in this case.

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Dated: May 30, 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 30, 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 30, 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 REQUEST
5:10-CV-04809-EJD