In re LinkedIn User Privacy Litigation

Filing 44

STIPULATION AND ORDER Granting Request Setting Date To Respond to Consolidated Amended Class Action Complaint re 42 Stipulation filed by Sam Veith, Linkedin Corporation, Katie Szpyrka, Candyce Paraggua, Scott Shepherd. Response due 11/5/2012. Signed by Judge Edward J. Davila on 9/14/2012. (ecg, COURT STAFF) (Filed on 9/14/2012)

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COOLEY LLP
MICHAEL G. RHODES (116127) ([e-mail])
MATTHEW D. BROWN (196972) ([e-mail])
WHITTY SOMVICHIAN (216083) ([e-mail])
101 California Street, 5th Floor
San Francisco, CA 94111-5800
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Defendant LINKEDIN CORPORATION
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*Admitted pro hac vice

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w a rd J .

Davila

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Attorneys for Plaintiffs

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JAY EDELSON* ([e-mail])
RAFEY S. BALABANIAN* ([e-mail])
ARI J. SCHARG* ([e-mail])
CHRISTOPHER L. DORE* ([e-mail])
EDELSON MCGUIRE LLC
350 North LaSalle Street, Suite 1300
Chicago, Illinois 60654
Telephone: [phone]
Fax: [phone]

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SEAN P. REIS (184044)
([e-mail])
EDELSON MCGUIRE LLP
30021 Tomas Street, Suite 300
Rancho Santa Margarita, California 92688
Telephone: [phone]

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9/14/2012

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
Case No. 12-CV-3088 EJD

IN RE LINKEDIN USER PRIVACY
LITIGATION

STIPULATION SETTING DATE TO
RESPOND TO CONSOLIDATED AMENDED
CLASS ACTION COMPLAINT

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Courtroom:
Judge:
Trial Date:

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4, 5th Floor
Hon. Edward J. Davila
None Set

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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

STIP. SETTING DATE TO RESPOND TO CONSOL. AMEND. COMPL.
(CASE NO. 12-CV-3088-EJD)

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This Stipulation is entered into by and among plaintiffs Katie Szpyrka, Candyce Paraggua,

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Scott Shepherd, and Sam Veith (collectively “Plaintiffs”) and Defendant LinkedIn Corporation

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(“LinkedIn”) (Plaintiffs and LinkedIn collectively the “Parties”), by and through their respective

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counsel.

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WHEREAS in Szpyrka v. LinkedIn Corp., Case No. 12-CV-3088 EJD, which is the first-

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filed action and lead case, plaintiff Szpyrka filed a Complaint in the United States District Court

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for the Northern District of California on June 15, 2012;

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WHEREAS a Waiver of the Service of Summons form in the Szpyrka action, executed by
LinkedIn’s counsel, has been filed;

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WHEREAS the previous deadline for LinkedIn to answer, move, or otherwise respond to

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the Complaint in the Szpyrka action was August 14, 2012 (60 days from the date on which

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plaintiff Szpyrka sent the request for waiver of service to LinkedIn);

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WHEREAS a Case Management Conference in the Szpyrka action was scheduled to occur
on August 31, 2012 (Dkt. No. 36);

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WHEREAS plaintiff Szpyrka and LinkedIn filed a Stipulation to Extend Time to Respond

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to Complaint on August 13, 2012 (Dkt. No. 35) pursuant to which LinkedIn’s deadline to answer,

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move, or otherwise respond to the Complaint in the Szpryka action was extended to 45 days after

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the date of the initial Case Management Conference in the Szpyrka action;

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WHEREAS the Plaintiffs in four related actions in this district (Szpyrka v. LinkedIn Corp.;

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Shepherd v. LinkedIn Corp.; Paraggua v. LinkedIn Corp.; and Veith v. LinkedIn Corp.) jointly

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filed a Motion to Consolidate and Motion to Appoint Interim Lead Class Counsel and Liaison

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Class Counsel on July 16, 2012 (“Motion to Consolidate”), seeking, among other things, to (1)

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consolidate the four actions for all purposes; and (2) grant plaintiffs leave to file a consolidated

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amended complaint (Dkt. No. 12);

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WHEREAS this Court issued an Order dated August 29, 2012 (Dkt. No. 40) that vacated

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the Case Management Conference that was previously set for August 31, 2012, and, among other

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things, (1) granted Plaintiffs’ Motion to Consolidate the four related actions in this district,

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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

STIP. SETTING DATE TO RESPOND TO CONSOL. AMEND. COMPL.
(CASE NO. 12-CV-3088-EJD)

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(2) designated the Szpyrka action as the lead action, and (3) ordered the filing of a consolidated

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amended class action complaint on or before September 19, 2012;

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WHEREAS the Parties have agreed that LinkedIn’s deadline to answer, move, or

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otherwise respond to the consolidated amended class action complaint will be 45 days after

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Plaintiffs’ deadline to file their consolidated amended class action complaint;

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WHEREAS under Civil Local Rule 6-1(a), parties may stipulate in writing, without a
court order, to extend the time within which to answer or otherwise respond to a complaint;
WHEREAS this stipulation will not alter the date of any event or deadline already fixed
by court order;

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

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

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class action complaint in this action will be November 5, 2012 (which is 45 days after the

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deadline for Plaintiffs to file their consolidated amended class action complaint, extended to the

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next court day).

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IT IS SO STIPULATED.
Dated: September 13, 2012

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COOLEY LLP

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By: /s/ Matthew D. Brown
Matthew D. Brown (196972)

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Attorneys for Defendant LINKEDIN CORP.

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Dated: September 13, 2012

EDELSON MCGUIRE LLC

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By: /s/ Ari J. Scharg
Ari J. Scharg

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Attorneys for Plaintiffs

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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

STIP. SETTING DATE TO RESPOND TO CONSOL. AMEND. COMPL.
(CASE NO. 12-CV-3088-EJD)

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ATTESTATION PURSUANT TO CIVIL LOCAL RULE 5-1(i)(3)
Pursuant to Civil Local Rule 5-1(i)(3), I, Matthew D. Brown, attest that concurrence in the
filing of this document has been obtained from each of the other signatories.

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Dated: September 13, 2012

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/s/ Matthew D. Brown__________________
Matthew D. Brown

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1059777 v1/HN

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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

STIP. SETTING DATE TO RESPOND TO CONSOL. AMEND. COMPL.
(CASE NO. 12-CV-3088-EJD)

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