Campbell et al v. Facebook Inc.

Filing 223

STIPULATION WITH PROPOSED ORDER Regarding Case Schedule filed by Facebook Inc.. (Jessen, Joshua) (Filed on 12/21/2016)

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GIBSON, DUNN & CRUTCHER LLP
JOSHUA A. JESSEN, SBN 222831
[e-mail]
JEANA BISNAR MAUTE, SBN 290573
[e-mail]
PRIYANKA RAJAGOPALAN, SBN 278504
[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,
Plaintiffs,

CASE NO. C 13-05996 PJH
STIPULATION AND [PROPOSED]
ORDER REGARDING CASE SCHEDULE

v.
FACEBOOK, INC.,
Defendant.

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Gibson, Dunn &
Crutcher LLP

STIPULATION AND [PROPOSED] ORDER
RE CASE SCHEDULE
No. C 13-05996 PJH

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WHEREAS, on November 23, 2016, the Court ordered that discovery in this case be stayed,

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and the existing case deadlines vacated, pending an update by the parties on or before December 23,

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2016 regarding whether a resolution had been reached (Dkt. 221);

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WHEREAS, concurrently with this Stipulation, the parties filed a Joint Status Report to notify

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the Court that the parties have reached a settlement-in-principle in this case, and intend to submit a

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written settlement agreement, and motion for preliminary approval of the settlement, on or before

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February 15, 2017;

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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: The stay on discovery and vacation of case deadlines

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previously ordered in this action shall remain in effect until February 15, 2017. In the event that a

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written settlement agreement and motion for preliminary approval are not submitted to the Court on

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or before February 15, 2017, the discovery stay is lifted, Facebook shall make its document

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production on that date, and the new case deadlines shall be as follows: non-expert discovery shall be

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completed by March 23, 2017; experts must be disclosed by May 11, 2017, and cross motions for

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summary judgment shall be filed by May 11, 2017.

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Respectfully submitted,
DATED: December 21, 2016

GIBSON, DUNN & CRUTCHER LLP

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By:

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Attorneys for Defendant Facebook, Inc.

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DATED: December 21, 2016

LIEFF CABRASER HEIMANN & BERNSTEIN

By:

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/s/
JOSHUA A. JESSEN

/s/
MICHAEL W. SOBOL

Attorneys for Plaintiffs

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Gibson, Dunn &
Crutcher LLP

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STIPULATION AND [PROPOSED] ORDER
RE CASE SCHEDULE
No. C 13-05996 PJH

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

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DATED: December 21, 2016

GIBSON, DUNN & CRUTCHER LLP

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By:

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/s/
JOSHUA A. JESSEN

Attorneys for Defendant Facebook, Inc.

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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 the stay on discovery and vacation

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of case deadlines previously ordered in this action shall remain in effect until February 15, 2017. In

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the event that a written settlement agreement and motion for preliminary approval are not submitted

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to the Court on or before February 15, 2017, the discovery stay is lifted, Facebook shall make its

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document production on that date, and the new case deadlines shall be as follows: non-expert

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discovery shall be completed by March 23, 2017; experts must be disclosed by May 11, 2017, and

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cross motions for summary judgment shall be filed by May 11, 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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STIPULATION AND [PROPOSED] ORDER
RE CASE SCHEDULE
No. C 13-05996 PJH