Freeza et al v. Google, Inc.

Filing 29

STIPULATION AND ORDER #28 for Adjournment of Case Management Conference. Signed by Judge Ronald M. Whyte on 8/23/12. (jg, COURT STAFF) (Filed on 8/23/2012)

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EDWARD D. JOHNSON (SBN 189475)
[e-mail]
ERIC B. EVANS (SBN 232476)
[e-mail]
JONATHAN A. HELFGOTT (SBN 278969)
[e-mail]
MAYER BROWN LLP
Two Palo Alto Square, Suite 300
3000 El Camino Real
Palo Alto, CA 94306-2112
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant
Google Inc.

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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RACHEL FREZZA and MAURO
RODRIGUEZ, on their own behalf and all
others similarly situated,
Plaintiffs,
v.
GOOGLE INC.,
Defendant.

CASE NO. 5:12-CV-00237-RMW
STIPULATED REQUEST FOR
ADJOURNMENT OF CASE
MANAGEMENT CONFERENCE

Pursuant to Civil Local Rules 6-1(b) and 6-2(a), this stipulated request is entered into

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between Counsel for Plaintiffs Rachel Frezza and Mauro Rodriguez (collectively “Plaintiffs”)

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and Defendant Google Inc. (“Google”).

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WHEREAS, on June 15, 2012, the Court held a hearing on Google’s Motion to Dismiss;

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WHEREAS, On July 18, 2012, the Court scheduled a Case Management Conference for
August 31, 2012 at 10:30 a.m.;
WHEREAS, on August 2, 2012, this Court entered a Minute Entry for the June 15, 2012

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hearing, which indicated that the Court would “defer scheduling a Case Management Conference

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until further notice,” and, as a result of the August 2 entry, Plaintiffs had understood that the

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August 31, 2012 Case Management Conference had been vacated;

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WHEREAS, the August 31 Case Management Conference still appears on this Court’s
docket; and
STIPULATED REQUEST FOR ADJOURNMENT OF CASE MANAGEMENT CONFERENCE
CASE NO. 5:12-CV-00237-RMW

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WHEREAS, the parties agree that they will be better able to prepare for, and productively

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participate in, the Case Management Conference after disposition of the pending motion to

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dismiss:

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IT IS HEREBY STIPULATED AND REQUESTED that the Case Management

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Conference currently scheduled for August 31, 2012 be adjourned until thirty days after this

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Court rules on Google’s Motion to Dismiss, or at the Court’s convenience following that date.

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Pursuant to Civil Local Rule 6-2(a)(2), the parties state that on February 2, 2012,

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Plaintiffs agreed to extend Google’s time to respond to the Complaint to March 16, 2012; on

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March 20, 2012, and on March 29, 2012 Google agreed to extend Plaintiffs’ time to file their

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opposition until April 20, 2012 and the parties stipulated that Google would have until May 4,

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2012 to file its reply.

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IT IS SO STIPULATED AND REQUESTED.

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DATED: August 20, 2012

MAYER BROWN LLP

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/s/ Edward D. Johnson
Edward D. Johnson (SBN 189475)
Eric B. Evans (SBN 232476)
Jonathan A. Helfgott (SBN 278969)
Two Palo Alto Square, Suite 300
3000 El Camino Real
Palo Alto, CA 94306
T: [phone]
F: [phone]
Attorneys for Defendant Google Inc.

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SIPRUT PC

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/s/ Joseph J. Siprut
Joseph J. Siprut (Pro Hac Vice)
17 North State Street, Suite 1600
Chicago, IL 60602
T: [phone]
F: [phone]
Attorneys for Plaintiffs Rachael
Frezza and Mauro Rodriguez

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-2STIPULATED REQUEST FOR ADJOURNMENT OF CASE MANAGEMENT CONFERENCE
CASE NO. 5:12-CV-00237-RMW

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[] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED THAT:
The Case Management Conference Scheduled for August 31, 2012 shall be adjourned until thirty
(30) days following entry of the Court’s Order on the pending Motion to Dismiss or at the
Court’s convenience following that date.

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Dated:
HON. RONALD M. WHYTE
UNITED STATES DISTRICT JUDGE

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-3STIPULATED REQUEST FOR ADJOURNMENT OF CASE MANAGEMENT CONFERENCE
CASE NO. 5:12-CV-00237-RMW