Veljanoski v. Juno Therapeutics, Inc. et al

Filing 76

ORDER granting 75 Stipulated Motion for Extension of Time to Answer by 7/21/17 signed by Judge Ricardo S Martinez.(RS)

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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In re JUNO THERAPEUTICS, INC.

CASE NO.: C16-1069 RSM
STIPULATED MOTION
PURSUANT TO LCR 7(j) AND 10(g)
TO EXTEND DEFENDANTS’ TIME
TO FILE ANSWER

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Pursuant to Local Civil Rule 7(j) and 10(g), Defendants Juno Therapeutics, Inc.

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(“Juno”), Hans Bishop, Dr. Steven Harr, and Dr. Mark J. Gilbert (collectively,

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“Defendants”), and Lead Plaintiff Gilbert Hoang Nguyen and named plaintiff Jiayi Wan

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(collectively, “Plaintiffs”), hereby stipulate and request that the Court extend the time for

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Defendants to file their Answer to the Plaintiffs’ Consolidated Amended Complaint [Dkt. #

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47] (the “Complaint”) to July 21, 2017, for the following reasons:

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Pursuant to a stipulated schedule approved by the Court on October 31, 2016 [Dkt. #

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44], Plaintiffs filed their Complaint on December 12, 2016, and Defendants filed a motion to

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dismiss the Complaint on February 2, 2017 [Dkt. # 55]. On June 14, 2017, the Court issued

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an Order Denying Defendants’ Motion to Dismiss [Dkt. # 74]. Under Federal Rule of Civil

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Procedure 12(a)(4)(A), Defendants’ Answer to the Complaint is currently due on June 28,

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2017. Because the Complaint includes four defendants and over 100 paragraphs of

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allegations, and due to long-standing vacation plans during the period in which the Answer

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must be prepared, Defendants require additional time to properly prepare their Answer to the

ORDER

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Complaint. Defendants asked, and Plaintiffs agreed that they would not oppose an extension

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until July 21, 2017 for Defendants to file their Answer to the Complaint. Defendants have

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also agreed to file their Answer on July 21, 2017 notwithstanding any possible interim

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motion to reconsider the Court’s Order Denying Defendants’ Motion to Dismiss.

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THEREFORE, for the reasons stated above, the parties request that the

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Court enter an Order allowing Defendants until July 21, 2017 within which to file

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their Answer to the Complaint.
Dated: June 21, 2017

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Dated: June 21, 2017

s/ Gregory L. Watts
Gregory L. Watts, WSBA #43995
WILSON SONSINI GOODRICH & ROSATI, PC
701 Fifth Avenue, Suite 5100
Seattle, Washington 98104
Telephone: [phone]
Facsimile: [phone]
Email:
[e-mail]
Attorney for Defendants Juno Therapeutics,
Inc., Hans E. Bishop, Steven D. Harr, and
Mark J. Gilbert
s/ Cliff Cantor
Cliff Cantor, WSBA #17893
LAW OFFICES OF CLIFFORD A.
CANTOR, P.C.
627 208th Ave. SE
Sammamish, Washington 98074
Telephone: [phone]
Facsimile: [phone]
Email:
[e-mail]
Attorney for Lead Plaintiff Gilbert Hoang
Nguyen and Named Plaintiff Jiayi Wan

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IT IS SO ORDERED this 21st day of June 2017.

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A

RICARDO S. MARTINEZ
CHIEF UNITED STATES DISTRICT JUDGE

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Submitted by:

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Gregory L. Watts, WSBA #43995
WILSON SONSINI GOODRICH & ROSATI, P.C.
701 Fifth Avenue, Suite 5100
Seattle, WA 98104-7036
Telephone: [phone]
Facsimile: [phone]
Email:

[e-mail]

Joni Ostler, Pro Hac Vice
WILSON SONSINI GOODRICH & ROSATI, PC
650 Page Mill Road
Palo Alto, CA 94304
Telephone: [phone]
Facsimile: [phone]
Email:
[e-mail]

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Attorney for Defendants Juno Therapeutics,
Inc., Hans E. Bishop, Steven D. Harr, and
Mark J. Gilbert