Campbell et al v. Facebook Inc.

Filing 220

STIPULATION WITH PROPOSED ORDER Regarding Case Schedule filed by Facebook Inc.. (Chorba, Christopher) (Filed on 11/22/2016) Modified on 11/23/2016 (vlkS, COURT STAFF).

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GIBSON, DUNN & CRUTCHER LLP
JOSHUA A. JESSEN, SBN 222831
[e-mail]
JEANA BISNAR MAUTE, SBN 290573
[e-mail]
ASHLEY M. ROGERS, SBN 286252
[e-mail]
1881 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]
GIBSON, DUNN & CRUTCHER LLP
CHRISTOPHER CHORBA, SBN 216692
[e-mail]
333 South Grand Avenue
Los Angeles, California 90071
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
FACEBOOK, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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MATTHEW CAMPBELL and MICHAEL
HURLEY,

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Plaintiffs,
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Case No. C 13-05996 PJH (SK)
JOINT STIPULATION AND
[PROPOSED] ORDER REGARDING
CASE SCHEDULE

v.
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FACEBOOK, INC.,
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Defendant.
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Gibson, Dunn &
Crutcher LLP

JOINT STIPULATION AND [PROPOSED] ORDER REGARDING CASE SCHEDULE
Case No. C 13-05996 PJH (SK)

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WHEREAS, on June 30, 2016, the Court held a Case Management Conference wherein the

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Court set the following deadlines: non-expert discovery shall be completed by November 30, 2016;

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experts must be disclosed by January 18, 2017; and cross motions for summary judgment shall be

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filed by January 18, 2017 (Dkt. 203);

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WHEREAS, at the Case Management Conference, the Court inquired about whether the

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parties had conducted a mediation, and suggested that the case might be well positioned for

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settlement in light of the Court’s order on class certification;

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WHEREAS, since the Case Management Conference, the parties have conducted two
mediation sessions with Cathy Yanni at JAMS and have had several additional discussions about
resolution of this matter;

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WHEREAS, the parties are continuing to make progress toward a resolution of this matter and
wish to focus their energies on those discussions;

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WHEREAS, the parties have scheduled another mediation session for December 7, 2016;

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WHEREAS, the parties also have been diligently pursuing the discovery ordered by the

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Court, but due to scheduling needs related to final depositions and other discovery, the parties require

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additional time to complete non-expert discovery, but wish to stay that discovery pending their

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further discussions; and

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WHEREAS, the parties have not previously requested any extension of the above-referenced
deadlines;

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NOW, THEREFORE, subject to the approval of the Court, and for good cause shown, the

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parties hereby stipulate and agree as follows: Discovery is stayed, and the existing case deadlines are

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vacated. The parties shall update the Court by December 23, 2016, regarding whether a resolution

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has been reached. In the event no resolution is reached by December 23, 2016, the discovery stay is

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lifted, Facebook shall make its document production on that date, and the new case deadlines shall be

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Gibson, Dunn &
Crutcher LLP

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JOINT STIPULATION AND [PROPOSED] ORDER REGARDING CASE SCHEDULE
Case No. C 13-05996 PJH (SK)

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as follows: non-expert discovery shall be completed by January 26, 2017; experts must be disclosed

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by March 16, 2017; and cross motions for summary judgment shall be filed by March 16, 2017.

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DATED: November 22, 2016

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LIEFF CABRASER HEIMANN & BERNSTEIN
By:

/s/
MICHAEL W. SOBOL

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Attorneys for Plaintiffs

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DATED: November 22, 2016

GIBSON, DUNN & CRUTCHER LLP

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By:

/s/
CHRISTOPHER CHORBA

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Attorneys for Defendant Facebook, Inc.

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Gibson, Dunn &
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JOINT STIPULATION AND [PROPOSED] ORDER REGARDING CASE SCHEDULE
Case No. C 13-05996 PJH (SK)

ATTORNEY ATTESTATION

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Pursuant to Civil Local Rule 5-1, I, Christopher Chorba, hereby attest that concurrence in the
filing of this document has been obtained from Michael W. Sobol.

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DATED: November 22, 2016

GIBSON, DUNN & CRUTCHER LLP

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By:

/s/
CHRISTOPHER CHORBA

Attorneys for Defendant Facebook, Inc.

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JOINT STIPULATION AND [PROPOSED] ORDER REGARDING CASE SCHEDULE
Case No. C 13-05996 PJH (SK)

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[PROPOSED] ORDER

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Having considered the Parties’ Stipulation, and good cause appearing, the Court hereby

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GRANTS the Parties’ stipulation. It is HEREBY ORDERED that: Discovery is stayed, and the

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existing case deadlines are vacated. The parties shall update the Court by December 23, 2016,

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regarding whether a resolution has been reached. In the event no resolution is reached by December

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23, 2016, the discovery stay is lifted, Facebook shall make its document production on that date, and

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the new case deadlines shall be as follows: non-expert discovery shall be completed by January 26,

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2017; experts must be disclosed by March 16, 2017; and cross motions for summary judgment shall

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be filed by March 16, 2017.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: ________________________
The Honorable Phyllis J. Hamilton
United States District Court Judge

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Gibson, Dunn &
Crutcher LLP

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JOINT STIPULATION AND [PROPOSED] ORDER REGARDING CASE SCHEDULE
Case No. C 13-05996 PJH (SK)