Heathcote v. Grande Games Limited

Filing 43

ORDER granting 42 Stipulated Motion re Defendants' Deadline to Respond to the First Amended Complaint. The deadline for Defendants to file answers or motions to dismiss in response to the First Amended Complaint is December 7, 2021. Signed by Judge Ricardo S. Martinez. (PM)

Case 2:20-cv-01310-RSM Document 43 Filed 09/08/21 Page 1 of 5

The Honorable Ricardo S. Martinez

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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WILLIAM HEATHCOTE, individually and on
behalf of all others similarly situated,
Plaintiff,

STIPULATED MOTION REGARDING
DEFENDANTS’ DEADLINE TO
RESPOND TO THE FIRST AMENDED
SPINX GAMES LIMITED, GRANDE GAMES COMPLAINT AND ORDER
LIMITED, and BEIJING BOLE
TECHNOLOGY CO., LTD.,
NOTE ON MOTION CALENDAR:
SEPTEMBER 3, 2021
Defendants.
v.

STIPULATION

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NO. 2:20-cv-01310-RSM

Plaintiff William Heathcote (“Plaintiff”) and Defendants SpinX Games Limited, Grande
Games Limited, and Beijing Bole Technology Co., Ltd. (“Defendants”) (collectively, the
“Parties”), by and through undersigned counsel, hereby stipulate as follows:
WHEREAS, the original Complaint in this action was filed on September 1, 2020 (Dkt.
#1);
WHEREAS, Plaintiff filed a First Amended Complaint on April 9, 2021 (Dkt. #14);
WHEREAS, Defendants agreed to waive service of process in exchange for 90 days to
respond to Plaintiff’s First Amended Complaint (Dkt. #35);
WHEREAS, on May 17, 2021, the Court granted the Parties’ request to extend
Defendants’ deadline to respond to Plaintiff’s First Amended Complaint from April 9, 2021
until August 9, 2021 (Dkt. # 39). On July 8, 2021 the Court granted the Parties’ request to
STIPULATED MOTION REGARDING DEFENDANTS’
DEADLINE TO RESPOND TO THE FIRST AMENDED
COMPLAINT AND ORDER (NO. 2:20-CV-01310-RSM) - 1

38TH FLOOR
1000 SECOND AVENUE
SEATTLE, WASHINGTON 98104
[phone]

Case 2:20-cv-01310-RSM Document 43 Filed 09/08/21 Page 2 of 5

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extend Defendants’ deadline to respond to Plaintiff’s First Amended Complaint from August
9, 2021 until October 8, 2021 to allow the parties to discuss information exchanges and early
informal discovery. Other than these extensions, there have been no prior extensions to, or
requests to extend, the deadline to respond to the First Amended Complaint;
WHEREAS, the Parties have agreed to mediate the present dispute, and mediation will
take place over two days, on October 20 and October 26, 2021;
WHEREAS, Plaintiff has assented to an additional 60-day extension of Defendants’
deadline to respond to Plaintiff’s First Amended Complaint, and the Parties agree that such an
extension will allow the Parties to focus their efforts on the upcoming mediation without
prejudicing either side and without altering the date of any other event or any other deadline
already fixed by the Court.
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by and
between the Parties to this action, through their undersigned counsel, and subject to the Court’s
approval, that the deadline for Defendants to file answers or motions to dismiss in response to
the First Amended Complaint shall be December 7, 2021.
DATED this 3rd day of September, 2021.
CARSON NOEL PLLC

BYRNES KELLER CROMWELL LLP

By /s/ Wright A. Noel
Wright A. Noel, WSBA #25264
20 Sixth Avenue NE
Issaquah, WA 98027
Telephone: [phone]
[e-mail]
Attorneys for Plaintiff

By /s/ John A. Tondini
John A. Tondini, WSBA #19092
1000 Second Avenue, 38th Floor
Seattle, WA 98104
Telephone: [phone]
[e-mail]
[e-mail]
Attorneys for Defendants

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STIPULATED MOTION REGARDING DEFENDANTS’
DEADLINE TO RESPOND TO THE FIRST AMENDED
COMPLAINT AND ORDER (NO. 2:20-CV-01310-RSM) - 2

38TH FLOOR
1000 SECOND AVENUE
SEATTLE, WASHINGTON 98104
[phone]

Case 2:20-cv-01310-RSM Document 43 Filed 09/08/21 Page 3 of 5

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Philip L. Fraietta (pro hac vice)
Alec M. Leslie (pro hac vice)
Bursor & Fisher, P.A.
888 Seventh Avenue
New York, NY 10019
Telephone: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff

Ajay S. Krishnan (pro hac vice)
Michelle Ybarra (pro hac vice)
Patrick E. Murray (pro hac vice)
Connie P. Sung (pro hac vice)
Keker, Van Nest & Peters LLP
633 Battery Street
San Francisco, CA 94111-1809
Telephone: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED this 8th day of September, 2021.

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A

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RICARDO S. MARTINEZ
CHIEF UNITED STATES DISTRICT JUDGE

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Presented by:
BYRNES KELLER CROMWELL LLP

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By:

/s/ John A. Tondini
John A. Tondini, WSBA #19092
1000 Second Avenue, 38th Floor
Seattle, WA 98104
Telephone: [phone]
[e-mail]
[e-mail]

Ajay S. Krishnan (pro hac vice)
Michelle Ybarra (pro hac vice)
Patrick E. Murray (pro hac vice)
Connie Sung (pro hac vice)
STIPULATED MOTION REGARDING DEFENDANTS’
DEADLINE TO RESPOND TO THE FIRST AMENDED
COMPLAINT AND ORDER (NO. 2:20-CV-01310-RSM) - 3

38TH FLOOR
1000 SECOND AVENUE
SEATTLE, WASHINGTON 98104
[phone]

Case 2:20-cv-01310-RSM Document 43 Filed 09/08/21 Page 4 of 5

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633 Battery Street
San Francisco, CA 94111-1809
Telephone:
[phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants

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STIPULATED MOTION REGARDING DEFENDANTS’
DEADLINE TO RESPOND TO THE FIRST AMENDED
COMPLAINT AND ORDER (NO. 2:20-CV-01310-RSM) - 4

38TH FLOOR
1000 SECOND AVENUE
SEATTLE, WASHINGTON 98104
[phone]

Case 2:20-cv-01310-RSM Document 43 Filed 09/08/21 Page 5 of 5

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CERTIFICATE OF SERVICE
The undersigned attorney certifies that on the 8th day of September, 2021, I
electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which
will send notification of such filing to all counsel on record in the matter.

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/s/ John A. Tondini
Byrnes Keller Cromwell LLP
1000 Second Avenue, 38th Floor
Seattle, WA 98104
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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STIPULATED MOTION REGARDING DEFENDANTS’
DEADLINE TO RESPOND TO THE FIRST AMENDED
COMPLAINT AND ORDER (NO. 2:20-CV-01310-RSM) - 5

38TH FLOOR
1000 SECOND AVENUE
SEATTLE, WASHINGTON 98104
[phone]