Low v. Linkedin Corporation

Filing 9

STIPULATION to Extend Time to Respond to Complaint re ( 1 ) and to Set Briefing Schedule for Motion to Dismiss by Linkedin Corporation. (Frankel, Simon) (Filed on 6/3/2011) Linkage added on 6/3/2011 (bw, COURT STAFF).

1
2
3
4

Simon J. Frankel (Bar No. 171552)
Mali B. Friedman (Bar No. 247514)
COVINGTON & BURLING LLP
One Front Street, 35th Floor
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]
Email: [e-mail]

5
6

Attorney for Defendant
LINKEDIN CORPORATION

7
8
9
10

Michael R. Reese (Bar No. 206773)
REESE RICHMAN LLP
875 Avenue of the Americas, 18th Floor
New York, New York 10001
Telephone:
[phone]
Facsimile:
[phone]
Email: [e-mail]

11
12
13
14
15

Sanford P. Dumain
Peter E. Seidman
Anne Marie Vu (Bar No. 238771)
MILBERG LLP
One Pennsylvania Plaza, 49th Floor
New York, New York 10119
Telephone:
[phone]
Facsimile:
[phone]
Email: [e-mail]

16
17

Attorneys for Plaintiff
KEVIN LOW

18

IN THE UNITED STATES DISTRICT COURT

19

FOR THE NORTHERN DISTRICT OF CALIFORNIA

20

SAN JOSE DIVISION

21
22

KEVIN LOW, individually and behalf of all
others similarly situated

23

Plaintiff,

24

v.

25

Civil Case No.: CV 11-01468 HRL
STIPULATION TO EXTEND TIME
TO RESPOND TO COMPLAINT
AND TO SET BRIEFING
SCHEDULE FOR MOTION TO
DISMISS (Local Rule 6-1(a))

LINKEDIN CORPORATION, a Delaware
corporation, and DOES 1 to 50 inclusive;

26
Defendants.
27
28

STIPULATION TO EXTEND TIME TO RESPOND TO
COMPLAINT AND TO SET BRIEFING SCHEDULE FOR
MOTION TO DISMISS (Local Rule 6-1(a))

Civil Case No.: CV 11-01468 HRL

This Stipulation is entered into by and among plaintiff Kevin Low (“Plaintiff”)

1
2

and defendant LinkedIn Corporation (“LinkedIn”), by and through their respective counsel.
WHEREAS the Complaint in this action was filed on March 28, 2011 and served

3
4

upon LinkedIn on March 30, 2011;
WHEREAS the current deadline for LinkedIn to answer, move to dismiss, or

5
6

otherwise respond to the Complaint is June 10, 2011;
WHEREAS under Civil Local Rule 6-1 (a), parties may stipulate in writing,

7
8

without a Court order, to extend the time within which to answer, move to dismiss, or otherwise

9

respond to the Complaint;
WHEREAS extending the date for LinkedIn to answer, move to dismiss, or

10
11

otherwise respond to the Complaint to and including June 17, 2011 will not alter the date of any

12

event or deadline already fixed by Court order, and the Parties wish to set out a briefing

13

schedule regarding a motion to dismiss to provide the Parties adequate time to brief the issues

14

fully;

15

NOW, THEREFORE, the Parties hereby stipulate and agree as follows:

16

LinkedIn’s deadline to answer, move to dismiss, or otherwise respond to the

17

Complaint is extended to and including June 17, 2011. Plaintiff’s deadline to file its Opposition

18

in response to any motion to dismiss filed by LinkedIn shall be August 1, 2011. LinkedIn’s

19

deadline to file its Reply Brief in response to any Opposition filed by Plaintiff shall be August

20

15, 2011. Any motion to dismiss filed by LinkedIn on or before June 17, 2011 shall be set for

21

hearing no earlier than August 29, 2011.

22

///

23

///

24

///

25

///

26

///

27

///

28

STIPULATION TO EXTEND TIME TO RESPOND TO
COMPLAINT AND TO SET BRIEFING SCHEDULE FOR
MOTION TO DISMISS (Local Rule 6-1(a))

2

Civil Case No.: CV 11-01468 HRL

1
2

IT IS SO STIPULATED.
DATED: June 3, 2011

REESE RICHMAN LLP

3
By:
4
5

/s/
Michael R. Reese
Attorneys for Plaintiff
KEVIN LOW

6
7

DATED: June 3, 2011

8

COVINGTON & BURLING LLP
By:

9
10

/s/
Simon J. Frankel
Attorneys for Defendant
LINKEDIN CORPORATION

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

STIPULATION TO EXTEND TIME TO RESPOND TO
COMPLAINT AND TO SET BRIEFING SCHEDULE FOR
MOTION TO DISMISS (Local Rule 6-1(a))

3

Civil Case No.: CV 11-01468 HRL

ECF CERTIFICATION

1
2

I, Simon J. Frankel, am the ECF User whose identification and password are being

3

used to file this Stipulation to Extend Time to Respond to Complaint and to Set Briefing

4

Schedule for Motion to Dismiss. In compliance with General Order 45.X.B, I hereby attest

5

that Michael R. Reese has concurred in this filing.

6
7

DATED: June 3, 2011

COVINGTON & BURLING LLP

8
By:

9

/s/
Simon J. Frankel

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

STIPULATION TO EXTEND TIME TO RESPOND TO
COMPLAINT AND TO SET BRIEFING SCHEDULE FOR
MOTION TO DISMISS (Local Rule 6-1(a))

4

Civil Case No.: CV 11-01468 HRL