Opinion
Case No. CV-11-04409-SI
11-30-2011
ELYSE WOOD and JACK HAUGHT, individually, and on behalf of all others similarly situated, Plaintiffs, v. MOTOROLA MOBILITY, INC., a Delaware corporation, Defendant.
CLINTON JUDD MCCORD ERIN LEE JEANETTE PFAFF EDWARDS WILDMAN PALMER LLP Attorneys for Defendant Motorola Mobility, Inc. SEAN P. REIS (184044) E DELSON RAFEY S. BALABANIAN (PHV) CHRISTOPHER L. DORE (PHV) E DELSON Attorneys for Plaintiffs and Putative Classes
CLINTON JUDD MCCORD
ERIN LEE JEANETTE PFAFF
EDWARDS WILDMAN PALMER LLP
Attorneys for Defendant
Motorola Mobility, Inc.
SEAN P. REIS (184044)
EDELSON MCGUIRE LLP
RAFEY S. BALABANIAN (PHV)
CHRISTOPHER L. DORE (PHV)
EDELSON MCGUIRE LLC
Attorneys for Plaintiffs and Putative
Classes
JOINT STIPULATION
EXTENDING THE PARTIES'
BRIEFING SCHEDULE ON
DEFENDANT'S MOTION TO
DISMISS COMPLAINT
Pursuant to Local Rule 6-1, Plaintiff Elyse Wood and Jack Haught, individually and on behalf of a class of similarly situated individuals ("Plaintiffs"), and Defendant Motorola Mobility, Inc. (collectively referred to herein as the "Parties"), by and through their respective counsel of record, hereby stipulate to modify the Parties' briefing schedule as it pertains to Defendant's Motion to Dismiss the Complaint as follows:
WHEREAS, on September 2, 2011, Plaintiffs filed their Class Action Complaint against Defendant.
WHEREAS, on October 24, 2011, the Parties' stipulated to extend Defendant's time to respond to Plaintiff's Complaint by twenty-one (21) days.
WHEREAS, on November 17, 2011, Defendant moved to dismiss Plaintiffs' Complaint.
WHEREAS, Plaintiffs' current deadline to respond to Defendant's Motion to Dismiss is December 1, 2011.
WHEREAS, in the interests of justice and in an effort to enhance judicial efficiency and preserve resources, the Parties have agreed to extend Plaintiffs' time to oppose Defendant's Motion to Dismiss as well as Defendant's time to reply in support of its motion.
WHEREAS, based on the foregoing, Plaintiffs have requested and Defendant has consented to extend Plaintiffs' time to file their opposition to Defendant's motion to December 12, 2011. The Parties have further agreed to extend Defendant's deadline to file any reply brief to December 22, 2011.
WHEREAS, this extension is not sought for any improper purpose.
WHEREAS, the extension of time sought will not alter the date of any event or deadline already fixed by Court Order, including the hearing date on Defendant's Motion to Dismiss.
NOW, THEREFORE, THE PARTIES HEREBY STIPULATE and AGREE, subject to the approval of the Court, that:
1. Plaintiff shall have until December 12, 2011, to file any opposition papers to Defendant's Motion to Dismiss;
2. Defendant shall have until December 22, 2011, to file any reply papers in support of its Motion to Dismiss.
Respectfully submitted,
EDWARDS WILDMAN PALMER LLP
By: Clinton J. McCord
Attorneys for Defendant Motorola
Mobility, Inc.
EDELSON MCGUIRE LLC
By: _______________
Rafey S. Balabanian
Attorneys for Plaintiffs
PURSUANT TO STIPULATION, IT IS SO ORDERED.
HONORABLE SUSAN ILLSTON
UNITED STATES DISTRICT JUDGE