In Re FACEBOOK INTERNET TRACKING LITIGATION

Filing 108

MOTION for Protective Order TEMPORARILY STAYING FURTHER DISCOVERY PENDING RESOLUTION OF MOTION TO DISMISS SECOND AMENDED CONSOLIDATED COMPLAINT, AND MEMORANDUM OF POINTS AND AUTHORITIES filed by Facebook Inc.. Motion Hearing set for 4/28/2016 09:00 AM in Courtroom 4, 5th Floor, San Jose before Hon. Edward J. Davila. Responses due by 3/16/2016. Replies due by 3/23/2016. (Attachments: #1 Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #2 Exhibit A to Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #3 Exhibit B to Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #4 Exhibit C to Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #5 Exhibit D to Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #6 Exhibit E to Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #7 Exhibit F to Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #8 Exhibit G to Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #9 Exhibit H to Declaration of Kyle C. Wong in Support of Defendant Facebook, Inc.'s Motion for Protective Order, #10 Proposed Order (Brown, Matthew) (Filed on 3/2/2016) Modified on 3/16/2016 (cv, COURT STAFF).

1
2
3
4
5

COOLEY LLP
MICHAEL G. RHODES (116127) ([e-mail])
MATTHEW D. BROWN (196972) ([e-mail])
JEFFREY M. GUTKIN (216083) ([e-mail])
KYLE C. WONG (224021) ([e-mail])
101 California Street
5th Floor
San Francisco, CA 94111-5800
Telephone:
[phone]
Facsimile:
[phone]

6
7

Attorneys for Defendant
FACEBOOK, INC.

8
UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA
10
SAN JOSE DIVISION
11
12
13

Case No. 5:12-md-02314 EJD

In re: FACEBOOK INTERNET TRACKING
LITIGATION

[PROPOSED] ORDER GRANTING
DEFENDANT FACEBOOK, INC.’S MOTION
FOR PROTECTIVE ORDER TEMPORARILY
STAYING FURTHER DISCOVERY PENDING
RESOLUTION OF MOTION TO DISMISS
SECOND AMENDED CONSOLIDATED
COMPLAINT

14
15
16
17

Date:
Time:
Judge:

18

April 28, 2016
9:00 a.m.
Hon. Edward J. Davila

19
20

Defendant Facebook, Inc.’s Motion for Protective Order Temporarily Staying Further

21

Discovery Pending Resolution of Motion to Dismiss Second Amended Consolidated Complaint

22

(“Motion”) was heard on April 28, 2016 at 9:00 a.m. in this Court. Counsel for Facebook and

23
counsel for Plaintiffs were in attendance and presented oral argument. Having considered the
24
25

parties’ papers filed in support of and in opposition to the motion, oral argument, and all other

26

materials properly considered by the Court, and good cause having been shown, the Court issues

27

the following findings and orders:

28
COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

1.

[PROPOSED] ORDER GRANTING DEFENDANT’S
MOTION FOR PROTECTIVE ORDER
CASE NO. 5:12-MD-02314 EJD

1

Good cause exists to stay discovery pending resolution of Facebook’s motion to dismiss

2

Plaintiffs’ Second Amended Consolidated Class Action Complaint and Facebook’s Motion

3

should be and hereby is GRANTED.

4
It is ORDERED that discovery is stayed pending resolution of Facebook’s motion to
5
6

dismiss Plaintiffs’ Second Amended Consolidated Class Action Complaint.

7
8

IT IS SO ORDERED.

9
10

Dated: _______________, 2016
_____________________________
Edward J. Davila
United States District Judge

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

2.

[PROPOSED] ORDER GRANTING DEFENDANT’S
MOTION FOR PROTECTIVE ORDER
CASE NO. 5:12-MD-02314 EJD