In re Google Referrer Header Privacy Litigation

Filing 59

STIPULATION WITH PROPOSED ORDER / Stipulated Request for Extension of Deadline to File Supplemental Materials filed by Google Inc.. (Attachments: #1 Declaration of Randall W. Edwards in Support of Stipulated Request, #2 Proposed Order)(Edwards, Randall) (Filed on 9/6/2013)

1
2
3
4
5
6
7
8
9
10

RANDALL W. EDWARDS (S.B. #179053)
[e-mail]
O'MELVENY & MYERS LLP
Two Embarcadero Center, 28th Floor
San Francisco, California 94111-3823
Telephone:
[phone]
Facsimile:
[phone]
EDWARD D. JOHNSON (S.B. #189475)
[e-mail]
ERIC B. EVANS (S.B. #232476)
[e-mail]
Two Palo Alto Square, Suite 300
El Camino Real
Palo Alto, CA 94306-2112
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant
Google Inc.

11
12

UNITED STATES DISTRICT COURT

13

NORTHERN DISTRICT OF CALIFORNIA

14

SAN JOSE DIVISION

15
16

In re GOOGLE REFERRER HEADER
PRIVACY LITIGATION

CLASS ACTION

17
18

______________________________________

19

This Document Relates To: All Actions

20
21

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

DECLARATION OF RANDALL W.
EDWARDS IN SUPPORT OF
STIPULATED REQUEST FOR
EXTENSION OF DEADLINE TO FILE
SUPPLEMENTAL MATERIALS
Place:
Judge:

Courtroom 1, 5th Floor
Hon. Edward J. Davila

22
23
24
25
26
27
28
EDWARDS DECL. ISO STIPULATED
REQUEST FOR EXTENSION
5:10-CV-04809-EJD

1

I, Randall W. Edwards, declare as follows:

2

1.

3

I am a member in good standing of the Bar of the State of California and a partner with

the law firm of O’Melveny & Myers, LLP, counsel for Defendant Google Inc. I make this

4
declaration of my own personal knowledge and, if called as a witness, would testify to the matters
5
6

set forth below.

7

2.

8

Settlement (ECF No. 52), Google did not oppose that motion, and the Court held a hearing on the

9

motion on August 23, 2013.

10
11

3.

On July 19, 2013, Plaintiffs filed a Motion for Preliminary Approval of Class Action

At the August 23, 2013 hearing on preliminary approval of the settlement agreement, the

Court requested certain supplemental information be submitted. Following discussion at the

12
13
14

hearing, the date for the submission was set for September 6, 2013. Ongoing discussions are
occurring regarding issues related to the submission and the confidentiality of the mediation

15

process. The Parties believe that an additional week will assist them in completing those

16

discussions.

17

4.

18

Since the Court entered the Order for Consolidation of Class Actions as Modified by the

Court (ECF No. 51), no modifications to the consolidated case schedule have been requested.

19
5.

The requested extension will not affect the date of any event or other deadline already

20
21
22

fixed by the Court in this case.
I declare under penalty of perjury under the laws of the United States and the State of

23

California that the foregoing is true and correct. Executed on September 6, 2013 in San

24

Francisco, CA.

25
26

/s/ Randall W. Edwards
Randall W. Edwards

27
28
EDWARDS DECL. ISO STIPULATED
REQUEST FOR EXTENSION
5:10-CV-04809-EJD