Lalo v. Apple, Inc et al

Filing 114

STIPULATION Stipulation Extending Defendant Quattro Wireless, Inc.'s Time to Respond to Consolidated Complaint by Quattro Wireless, Inc.. (Charlson, Michael) (Filed on 5/19/2011)

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Michael L. Charlson (Bar No. 122125)
Maren J. Clouse (Bar No. 228726)
HOGAN LOVELLS US LLP
525 University Avenue, 4th Floor
Palo Alto, California 94301
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
[e-mail]

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Attorneys for Defendant
QUATTRO WIRELESS, 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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In re iPhone Application Litigation

Case No. CV-10-5878 LHK (PSG)
STIPULATION EXTENDING
DEFENDANT QUATTRO WIRELESS,
INC.’S TIME TO RESPOND TO
CONSOLIDATED COMPLAINT

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The Honorable Lucy H. Koh

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H OGAN L OVEL LS US
LLP
ATT ORNE YS AT LA W
PALO AL TO

STIPULATION EXTENDING QUATTRO’S TIME
TO RESPOND; Case No. CV 10-5878 LHK

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WHEREAS on April 7, 2011, the Court entered an Order providing that Plaintiffs shall

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file a Consolidated Complaint (“Complaint”) and Defendants shall answer, move, or otherwise

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respond within 30 days from the filing of the Complaint (Dkt. No. 66);

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WHEREAS Defendant Quattro Wireless, Inc. (“Quattro”) was named as a defendant in
the underlying action captioned Rodimer, et al. v. Apple, Inc., et al., Case No. CV-11-0700 PSG;

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WHEREAS the Rodimer action was consolidated with these actions pursuant to

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Stipulation and Order Consolidating Cases entered by the Court on March 15, 2011 (Dkt. No.

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36);

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WHEREAS Quattro does not believe that it was properly served in the Rodimer action

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and had not appeared in that action or these consolidated actions until now and was therefore not

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subject to the April 7, 2011 Order;

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WHEREAS Plaintiffs filed the Consolidated Complaint on April 21, 2011 (Dkt. No. 71);

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WHEREAS Plaintiffs have agreed to give defendants newly named, or defendants

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previously named but that did not previously appear in the pre-consolidation actions, until June

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13, 2011 to respond to the Consolidated Complaint;

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WHEREAS under Civil Local Rule 6-1(a), parties may stipulate in writing, without a

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Court order, to extend the time within which to answer, move, or otherwise respond to the

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Complaint; AND

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WHEREAS allowing Quattro until June 13, 2011 to answer, move, or otherwise respond

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to the Consolidated Complaint will not alter the date of any event or deadline fixed by Court

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order;

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ACCORDINGLY, IT IS HEREBY STIPULATED AND AGREED that Quattro has until
June 13, 2011 to respond to the Consolidated Complaint.

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H OGAN L OVEL LS US
LLP
ATT ORNE YS AT LA W
PALO AL TO

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STIPULATION EXTENDING QUATTRO’S TIME
TO RESPOND; Case No. CV 10-5878 LHK

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IT IS SO STIPULATED AND AGREED.

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DATED: May 19, 2011

HOGAN LOVELLS US LLP

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By /s/ Michael L. Charlson
Michael L. Charlson

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Attorneys for Defendant
QUATTRO WIRELESS, INC.

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Dated: May 19, 2011

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By: /s/ Scott A. Kamber
Scott A. Kamber (Admitted Pro Hac Vice)

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SCOTT A. KAMBER (Admitted Pro Hac Vice)
DAVID A. STAMPLEY (Admitted Pro Hac Vice)
KAMBERLAW, LLC
100 Wall Street, 23nd Floor
New York, New York 10005
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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DEBORAH KRAVITZ
KAMBERLAW, LLP
141 North Street
Healdsburg, California 95448
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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Interim Class Counsel

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ATTESTATION

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KAMBERLAW, LLP

Pursuant to General Order No. 45, Section X (B), I, Michael L. Charlson, attest that Scott

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Kamber has read and approved the Stipulation Extending Time for Defendant Quattro Wireless

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Inc.’s Response to Consolidated Complaint and consents to its filing in this action.

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DATED: May 19, 2011

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/s/ Michael L. Charlson
Michael L. Charlson

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H OGAN L OVEL LS US
LLP
ATT ORNE YS AT LA W
PALO AL TO

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STIPULATION EXTENDING QUATTRO’S
TIME TO RESPOND; Case No. CV 10-5878 LHK