Robert Heath v. Google Inc.

Filing 20

ORDER GRANTING 19 STIPULATION TO ENLARGE TIME FOR DEFENDANT GOOGLE INC. TO RESPOND TO PLAINTIFFS AMENDED COMPLAINT PURSUANT TO LOCAL RULE 6-1. Signed by Judge Beth Labson Freeman on 7/10/2015. (blflc3, COURT STAF) (Filed on 7/10/2015)

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Thomas M. McInerney, CA Bar No. 162055
[e-mail]
Jill V. Cartwright, CA Bar No. 260519
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
Steuart Tower, Suite 1300
One Market Plaza
San Francisco, CA 94105
Telephone:
415.442.4810
Facsimile:
415.442.4870
Attorneys for Defendant
GOOGLE INC.
Daniel L. Low, CA Bar No. 218387
[e-mail]
Kotchen & Low LLP
1745 Kalorama Road NW, Suite 101
Telephone:
202.841.7164
Facsimile:
202.280.1128
Attorneys for Plaintiffs
ROBERT HEATH and CHERYL FILLEKES

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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ROBERT HEATH, and
CHERYL FILLEKES,
Plaintiffs, on behalf of themselves and others
similarly situated,
Plaintiffs,

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Case No. 15-cv-01824-BLF
STIPULATION TO ENLARGE TIME FOR
DEFENDANT GOOGLE INC. TO
RESPOND TO PLAINTIFFS’ AMENDED
COMPLAINT PURSUANT TO LOCAL
RULE 6-1

v.

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GOOGLE INC., a Delaware corporation,

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Defendant.

Complaint Filed: April 22, 2015
Trial Date:
Not Set

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Case No. 15-cv-01824-BLF
STIPULATION TO ENLARGE TIME FOR DEFENDANT GOOGLE INC. TO RESPOND TO
PLAINTIFFS’ AMENDED COMPLAINT PURSUANT TO LOCAL RULE 6-1

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This stipulation is entered into by and between Plaintiffs Robert Health and Cheryl Fillekes

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(“Plaintiffs”), on the one hand, and Defendant Google Inc. (“Defendant”), on the other hand, by

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and through their undersigned counsel of record, with reference to the following facts and recitals:

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WHEREAS, the Complaint in this action was filed on April 22, 2015, and served on May 7,
2015;
WHEREAS, on June 11, 2015, Defendant filed a motion to dismiss pursuant to Rule 12 of
the Federal Rules of Civil Procedure (“FRCP”).
WHEREAS, on June 25, 2015, Plaintiffs filed an Amended Complaint (ECF No. 18). The
Amended Complaint added a second named plaintiff, Cheryl Fillekes, along with additional factual
allegations pertaining to her claims against Defendant.
WHEREAS, pursuant to FRCP 15(a)(3) and 6(d), the last day for Defendant to respond to
the Amended Complaint is July 13, 2015.
WHEREAS, Defendant needs additional time to investigate the new allegations in the

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Amended Complaint pertaining to Ms. Fillekes to appropriately respond to the Amended

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Complaint.

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WHEREAS, the stipulated deadline will not alter the date of any event or any deadline
already fixed by Court order.
It is therefore STIPULTED AND AGREED, by and between the undersigned counsel and

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pursuant to Civil Local Rule 6-1(a), that the time for Defendant to answer, move, or otherwise

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respond to the Complaint on file in this action is extended up to and including July 29, 2015.

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DATED: July 8, 2015

OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

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By:

/s/ Jill V. Cartwright
Thomas M. McInerney
Jill V. Cartwright

Attorneys for Defendant
GOOGLE INC.

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Case No. 15-cv-01824-BLF
STIPULATION TO ENLARGE TIME FOR DEFENDANT GOOGLE INC. TO RESPOND TO
PLAINTIFFS’ AMENDED COMPLAINT PURSUANT TO LOCAL RULE 6-1

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DATED: July 8, 2015

KOTCHEN & LOW LLP

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By:

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/s/ Daniel Low
Daniel Low

Attorneys for Plaintiffs
ROBERT HEATH and
CHERYL FILLEKES

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21756289.1

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SIGNATURE ATTESTATION

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Pursuant to Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this

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document has been obtained from the other signatories.

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DATED: July 9, 2015

By:

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/s/ Jill Cartwright
Jill V. Cartwright

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: July 10, 2015
The Honorable Beth Labson Freeman
United States District Judge

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21756289.1

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Case No. 15-cv-01824-BLF
STIPULATION TO ENLARGE TIME FOR DEFENDANT GOOGLE INC. TO RESPOND TO
PLAINTIFFS’ AMENDED COMPLAINT PURSUANT TO LOCAL RULE 6-1