Zard v. Groupon, Inc.

Filing 3

STIPULATION to Extend Time by Groupon, Inc., Brian Zard. (Bona, Jarod)

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Brian Zard, on behalf of himself
and other individuals similarly situated,

Civil Action No.:11-cv-00605 PAM/FLN

Plaintiff,
STIPULATION TO EXTEND TIME
v.
Groupon, Inc., a Delaware Corporation,
Defendant.

The undersigned parties through their respective attorneys hereby stipulate and
agree as follows:
1. On or about March 8, 2011, Plaintiff filed a Complaint in this Court against
Groupon, Inc..
2. On or about March 15, 2011, Groupon was served with the Complaint.
3. The time for Defendant to answer or otherwise respond to the Complaint is
April 5, 2011, pursuant to Fed. R. Civ. P. 12.
4. On or about March 11, 2011, plaintiffs in two other actions against Groupon1
filed with the Judicial Panel on Multidistrict Litigation a motion to transfer this case,
along with eight other cases to the Northern District of California.

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Ferreira v. Groupon, Inc., No. 11-cv-0132-DMS(POR) (S.D. Cal. filed Jan. 21, 2011)
and Gosling v. Groupon, Inc., No. 11-cv-01038-CRB (N.D. Cal. filed Mar. 4. 2011).

5. In light of these developments, the parties have agreed to extend the time for
Defendant to answer or otherwise respond to the Complaint an additional 30 days to
Thursday, May 5, 2011.
6. The parties would like to formally acknowledge their agreement and hereby
stipulate and agree that Defendant shall have an extension of time until May 5, 2011 to
answer or otherwise respond to the Complaint.
IT IS SO STIPULATED.
Stipulated to:
Date: March 24, 2011

By: s/Myles A. Schneider
Myles A. Schneider, Bar No. 305479
MYLES A. SCHNEIDER & ASSOC., LTD.
710 Dodge Avenue NW, Suite A
Elk River, MN 55330
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Andrew S. Friedman
Elaine A. Ryan
Patricia N. Syverson
BONNETT, FAIRBOURN, FRIEDMAN
& BALINT, P.C.
2901 N. Central Avenue, Suite 1000
Phoenix, AZ 85012
Telephone: [phone]
Facsimile: [phone]
Todd D. Carpenter
BONNETT, FAIRBOURN, FRIEDMAN
& BALINT, P.C.
600 W. Broadway, Suite 900
San Diego, CA 92101
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff Brian Zard
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Date: March 24, 2011

By: s/Jarod M. Bona
Jarod M. Bona, Bar No. 388860
DLA PIPER LLP (US)
90 South Seventh Street, Suite 5100
Minneapolis, MN 55402
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Shirli F. Weiss
Christopher M. Young
DLA PIPER LLP (US)
401 B Street, Suite 1700
San Diego, CA 92101
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant Groupon, Inc.

EAST\44422023.1

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