O'Rourke-v-Comcast Corp et al

Filing 32

STIPULATION AND ORDER GRANTING re 31 Stipulation to Extend Time to Respond to Complaint filed by Comcast Corporation, Lawrence Salva. The deadline for Defendants to answer, move, or otherwise respond to Plaintiff's Complaint shall be e xtended sine die, through and including 10 days after the conclusion of the early settlement conference. This stipulation will not alter the date of any event or any deadline already fixed by Court order. The filing of this stipulation does not in any way amount to Defendant Salva's consent to jurisdiction or waive his right to object to jurisdiction in this Court. Signed by Judge Edward J. Davila on 1/14/2015. (ecg, COURT STAFF) (Filed on 1/14/2015)

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S

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Attorneys for Defendants Comcast Corporation
and Lawrence Salva

DATED: 1/14/2015

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D IS T IC T
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DAVIS WRIGHT TREMAINE LLP

R NIA

J . D av i l

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J u d ge E

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NO

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ERED

O ORD
IT IS S

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S DISTRICT
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Thomas R. Burke (CA State Bar No. 141930)
[e-mail]
John D. Seiver (Admitted pro hac vice)
[e-mail]
Deborah A. Adler (CA State Bar No. 209525)
[e-mail]
Sanjay M. Nangia (CA State Bar No. 264986)
[e-mail]
DAVIS WRIGHT TREMAINE LLP
505 Montgomery Street, Suite 800
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]

UNIT
ED

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NORTHERN DISTRICT OF CALIFORNIA

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C

UNITED STATES DISTRICT COURT

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OF

SAN JOSE DIVISION

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CONAL O’ROURKE, an individual;
Plaintiff,
vs.
COMCAST CORPORATION, a Pennsylvania
Corporation; LAWRENCE SALVA, an
individual; and DOES 1-20, unknown
individuals;
Defendants.

Case No. 5:14-cv-04637-EJD
STIPULATION TO EXTEND TIME FOR
DEFENDANTS TO RESPOND TO
COMPLAINT
[Civ. L.R. 6-1(a)]

WHEREAS, on October 16, 2014, Plaintiff Conal O’Rourke (“Plaintiff”) filed a Complaint
against Defendants Comcast Corporation (“Comcast”), Lawrence Salva (“Salva”), and DOES 1-20
(“Does”) (collectively, “Defendants”);
WHEREAS, Defendants were served on different days;
WHEREAS, Plaintiff and Defendants stipulated, and the Court ordered, to extend the
deadline for Comcast and Salva to answer, move, or otherwise respond to Plaintiff’s Complaint up
to and including January 14, 2015; and

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STIPULATION FOR EXTENSION TO RESPOND TO COMPLAINT
Case No. 5:14-cv-04637-PSG
DWT 25910472v1 0107080-000265

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WHEREAS, Defendant Salva contends that this Court lacks personal jurisdiction and that

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the filing of this stipulation does not in any way amount to consent to jurisdiction or waive his

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right to object to jurisdiction in this Court;

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WHEREAS, on January 5, 2015, Plaintiff and Defendants requested the Court assign this

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case to an early settlement conference, and on January 7, 2015, the Court granted the request,

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referring the case to Magistrate Judge Paul S. Grewal;

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NOW THEREFORE, Plaintiff and Defendants HEREBY STIPULATE AND AGREE AS
FOLLOWS:
1.

The deadline for Defendants to answer, move, or otherwise respond to Plaintiff’s

DAVIS WRIGHT TREMAINE LLP

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Complaint shall be extended sine die, through and including 10 days after the conclusion of the

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early settlement conference.

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2.

This stipulation will not alter the date of any event or any deadline already fixed by

Court order.
3.

The filing of this stipulation does not in any way amount to Defendant Salva’s

consent to jurisdiction or waive his right to object to jurisdiction in this Court.
IT IS SO STIPULATED.
DATED: January 13, 2015

DAVIS WRIGHT TREMAINE LLP

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By:

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Thomas R. Burke (CA State Bar No. 141930)
[e-mail]
John D. Seiver (Admitted pro hac vice)
[e-mail]
Deborah Adler (CA State Bar No. 209525)
[e-mail]
Sanjay M. Nangia (CA State Bar No. 264986)
[e-mail]
DAVIS WRIGHT TREMAINE LLP
505 Montgomery Street, Suite 800
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]

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/s/ Thomas R. Burke

Attorneys for Defendants Comcast Corporation
and Lawrence Salva

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STIPULATION FOR EXTENSION TO RESPOND TO COMPLAINT
Case No. 5:14-cv-04637-PSG
DWT 25910472v1 0107080-000265

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DATED: January 13, 2015

DHILLON LAW GROUP INC.

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By:

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Harmeet K. Dhillon (CA State Bar No. 207873)
[e-mail]
Krista L. Baughman (CA State Bar No. 264600)
[e-mail]
John-Paul S. Deol (CA State Bar No. 284893)
[e-mail]
DHILLON LAW GROUP INC.
177 Post Street, Suite 700
San Francisco, CA 94108
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff Conal O’Rourke

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/s/ Harmeet K. Dhillon

DAVIS WRIGHT TREMAINE LLP

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ATTESTATION
I, Deborah A. Adler, hereby attest that concurrences in the filing of this document have
been obtained from each of the signatories.

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/s/ Deborah A. Adler
Deborah A. Adler

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STIPULATION FOR EXTENSION TO RESPOND TO COMPLAINT
Case No. 5:14-cv-04637-PSG
DWT 25910472v1 0107080-000265

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PROOF OF SERVICE
I, Natasha Majorko, declare under penalty of perjury under the laws of the State of
California that the following is true and correct:
I, the undersigned, hereby declare that I am over the age of eighteen years and not a party
to this action. I am employed, or am a resident of the County of San Francisco, California, and my
business address is: DAVIS WRIGHT TREMAINE LLP, and my business address is 505
Montgomery Street, Suite 800, San Francisco, California 94111-6533
On January 13, 2015, I caused to be served the following document(s):

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•

STIPULATION FOR EXTENSION TO RESPOND TO COMPLAINT

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on the interested party (ies) in this action by placing a true copy thereof and addressed as follows:

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Harmeet K. Dhillon (CA State Bar No. 207873)
Krista L. Baughman (CA State Bar No. 264600)
John-Paul S. Deol (CA State Bar No. 284893)
DHILLON LAW GROUP INC.
177 Post Street, Suite 700
San Francisco, CA 94108
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
[e-mail]
[e-mail]

DAVIS WRIGHT TREMAINE LLP

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Attorneys for Plaintiff Conal O’Rourke

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(By ELECTRONIC SERVICE VIA CM/ECF SYSTEM) In accordance with the
electronic filing procedures of this Court, service has been effected on the parties above,
whose counsel of record is a registered participant of CM/ECF, via electronic service
through the CM/ECF system.

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(By MAIL SERVICE) I then sealed each envelope and, with postage thereon fully prepaid
postage, I placed each for deposit with United States Postal Service, this same day, at my
business address shown above, following ordinary business practices.
(By PERSONAL SERVICE) I delivered such envelope by hand to the office of the
addressee.

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STIPULATION FOR EXTENSION TO RESPOND TO COMPLAINT
Case No. 5:14-cv-04637-PSG
DWT 25910472v1 0107080-000265

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DAVIS WRIGHT TREMAINE LLP

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(By FACSIMILE) I transmitted the documents by facsimile machine, pursuant to California
Rules of Court, Rule 2.306. The facsimile machine I used complied with Rule 2.301 and no
error was reported by the machine. The transmitting facsimile machine number is (619)
615-0700. The fax number of the party being served is listed above. Pursuant to Rule 2.306,
I caused the machine to print a transmission record of the transmission, a copy of which is
attached to this declaration.
(By OVERNIGHT DELIVERY) I deposited in a box or other facility regularly maintained
by the express service carrier, or delivered to a courier or driver authorized by the express
service carrier to receive documents, in an envelope or package with delivery fees paid or
provided for, and addressed on whom it is to be served pursuant to Code of Civil Procedure
section 10 13(c).
(By E-MAIL OR ELECTRONIC TRANSMISSION) Based on a court order or an
agreement of the parties to accept service by e-mail or electronic transmission, I caused the
documents to be sent to the person(s) at the email addresses listed above. I did not receive,
within a reasonable time after the transmission, any electronic message or other indication
that the transmission was unsuccessful.
I declare that I am employed by the office of a member of the bar of this court at whose
direction the service was made.
Executed January 13, 2015, at San Francisco, California.

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/s/ Natasha Majorko
Natasha Majorko

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STIPULATION FOR EXTENSION TO RESPOND TO COMPLAINT
Case No. 5:14-cv-04637-PSG
DWT 25910472v1 0107080-000265

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