Moore v. Apple Inc.

Filing 19

STIPULATION WITH PROPOSED ORDER STIPULATION AND [PROPOSED] ORDER TO AMEND BRIEFING DEADLINES PERTAINING TO DEFENDANT APPLE INC.'S MOTION TO DISMISS CLASS ACTION COMPLAINT filed by Adrienne Moore. (Katriel, Roy) (Filed on 8/6/2014)

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ROY A. KATRIEL (CA SBN 265463)
[e-mail]
THE KATRIEL LAW FIRM
4225 Executive Square, Suite 600
La Jolla, California 92037
Telephone: [phone]
Facsimile: 858.430.3719

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Attorneys for Plaintiff Adrienne Moore

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DAVID M. WALSH (CA SBN 120761)
[e-mail]
KAI S. BARTOLOMEO (CA SBN 264033)
[e-mail]
MORRISON & FOERSTER LLP
707 Wilshire Boulevard
Los Angeles, California 90017-3543
Telephone: [phone]
Facsimile: 213.892.5454

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TIFFANY CHEUNG (CA SBN 211497)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: 415.268.7522

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Attorneys for Defendant Apple Inc.

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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ADRIENNE MOORE, On Behalf of Herself and
All Others Similarly Situated,

Case No.

CV 14-2269 LHK

CLASS ACTION
Plaintiff,

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v.
APPLE INC.,
Defendant.

STIPULATION AND
[PROPOSED] ORDER TO
AMEND BRIEFING DEADLINES
PERTAINING TO DEFENDANT
APPLE INC.’S MOTION TO
DISMISS CLASS ACTION
COMPLAINT

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[N.D. CAL. CIVIL L.R. 6-1(b), 6-2]
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Hon. Lucy H. Koh
Complaint Filed: May 15, 2014
Trial Date: None Set

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Stip And [Proposed] Order To Amend Briefing
Deadlines Re: Apple’s Mtn To Dismiss

Moore v. Apple Inc.,
No. 5:14-cv-2269-LHK

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Pursuant to Civil Local Rules 6-1(b) and 6-2, Plaintiff Adrienne Moore and Defendant

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Apple Inc., through their respective attorneys, hereby stipulate, subject to Court approval, as

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follows:

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WHEREAS, Plaintiff filed her Complaint in this case on May 15, 2014;

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WHEREAS, on June 6, 2014 and on July 21, 2014, the parties stipulated to allow Apple

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additional time to respond to the Complaint until and including July 24, 2014;
WHEREAS, on July 24, 2014, Apple timely filed a Motion to Dismiss Moore’s Class

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Action Complaint, and noticed a hearing on the Motion for November 13, 2014 at 1:30 p.m.--the

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then first available hearing date on the Court’s calendar;

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WHEREAS, Moore’s Response to Apple’s Motion to Dismiss is due on or before August
7, 2014;
WHEREAS, the parties have conferred regarding scheduling conflicts, including briefing

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and court appearance obligations of Moore’s counsel, and have agreed to stipulate to extending

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Plaintiff’s time to respond to Apple’s Motion and Apple’s time to reply;

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WHEREAS, counsel for the parties have telephonically met and conferred and agreed

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upon an amended briefing schedule that would leave the hearing date on Apple’s motion

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unchanged;

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WHEREAS, Moore’s counsel has never sought any extension as to this motion or any
other deadline in this action;
Pursuant to Local Rules 6-1(b) and 6-2, IT IS HEREBY STIPULATED AND AGREED

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by the parties that, subject to Court approval, the briefing schedule on Apple’s pending motion to

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dismiss shall be modified as follows:

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1. Moore’s Response to Apple’s Motion To Dismiss the Class Action Complaint shall be
filed on or before August 21, 2014;
2. Apple’s Reply In Support Of Its Motion To Dismiss the Class Action Complaint Shall
be filed on or before September 18, 2014;

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3. The November 11, 2014 hearing date on Apple’s Motion To Dismiss shall remain on

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calendar and unchanged, and there is no other deadline currently fixed by the Court in

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this action that would be affected by this Stipulation.

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Dated: August 6, 2014

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DAVID M. WALSH
TIFFANY CHEUNG
KAI S. BARTOLOMEO
MORRISON & FOERSTER LLP

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By: /s/ Tiffany Cheung
Tiffany Cheung

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Attorneys for Defendant
APPLE INC.

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Dated: August 6, 2014

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ROY A. KATRIEL
THE KATRIEL LAW FIRM

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By: /s/ Roy A. Katriel
ROY A. KATRIEL

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Attorneys for Plaintiff
ADRIENNE MOORE

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IT IS SO ORDERED.

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Dated: ________________,2014

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Hon. Lucy H. Koh
United States District Judge

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Filer’s Attestation: I, Roy A. Katriel, am the ECF user whose ID and password are being

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used to file this Stipulation. In compliance with Civil Local Rule 5-1(i)(3), I hereby attest that

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Tiffany Cheung has concurred in this filing.

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Dated: August 6, 2014

/s/ Roy A. Katriel
_________________________
ROY A. KATRIEL
THE KATRIEL LAW
Attorney for Plaintiff
ADRIENNE MOORE

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