Opinion
2:23-cv-00491-TL
07-11-2024
ANDREA GLADSTONE, individually and on behalf of all others similarly situated, Plaintiff, v. AMAZON WEB SERVICES, INC., Defendant.
Erin K. Earl, Ryan Spear, Nicola C. Menaldo, Jordan Harris, PERKINS COIE LLP Counsel for Defendant Amazon Web Services, Inc. Wright A. Noel CARSON NOEL PLLC Joseph I. Marchese Max S. Roberts BURSOR & FISHER, P.A. Neal J. Deckant BURSOR & FISHER, P.A. Counsel for Plaintiff Andrea Gladstone.
Erin K. Earl, Ryan Spear, Nicola C. Menaldo, Jordan Harris, PERKINS COIE LLP Counsel for Defendant Amazon Web Services, Inc.
Wright A. Noel CARSON NOEL PLLC Joseph I. Marchese Max S. Roberts BURSOR & FISHER, P.A. Neal J. Deckant BURSOR & FISHER, P.A. Counsel for Plaintiff Andrea Gladstone.
STIPULATED MOTION AND [PROPOSED] ORDER TO EXTEND ANSWER DEADLINE AND DEADLINES TO SUBMIT PROPOSED PROTECTIVE ORDER AND ESI PROTOCOL
Tana Lin United States District Judge.
Pursuant to Judge Lin's Standing Order for All Civil Cases and Local Civil Rules 7(d)(1) and 10(g), Defendant Amazon Web Services, Inc. (“AWS”) and Plaintiff Andrea Gladstone (“Plaintiff,” and together with AWS, “the Parties”) jointly move to extend the deadlines to submit a proposed Protective Order and ESI Protocol from July 16, 2024, to August 13, 2024.
In addition, AWS respectfully moves for a brief extension of the deadline for AWS to file its answer to the Second Amended Class Action Complaint (“SAC”) (Dkt. 18) from July 16, 2024, to August 13, 2024. AWS has consulted with Plaintiff's counsel and Plaintiff does not object to this requested relief.
In support of the foregoing request for relief, the Parties state as follows:
1. The Court denied AWS's Motion to Dismiss the SAC on July 2, 2024. (Dkt. 44.)
2. The Parties previously jointly proposed submitting a proposed Protective Order and a proposed Agreement re: Discovery of Electronically Stored Information (“ESI Protocol”) within 14 days of the Court's ruling on AWS's Motion to Dismiss, which would make those proposals likewise due on July 16, 2024. (Dkt. 25.)
3. Pursuant to Federal Rule of Civil Procedure 12(a)(4), AWS's deadline to file its answer to the SAC is July 16, 2024.
4. On July 10, 2024, the Parties met and conferred to discuss pretrial deadlines. Consistent with the Court's Order re: Parties' Joint Status Report (Dkt. 29) and Order on Motion to Dismiss (Dkt. 44), the Parties anticipate submitting a Second Joint Status Report proposing pretrial deadlines on July 16, 2024.
5. Given the complexity of this case, the Court's recent order denying AWS's Motion to Dismiss, and the intervening Independence Day holiday, AWS requires additional time to prepare its answer to the SAC. The Parties also have conferred and agree that they require additional time to meet and confer regarding a proposed Protective Order and ESI Protocol. Good cause exists for these extensions based on the complexity of the matter, the current procedural posture, and pre-planned absences of the Parties and their counsel.
6. In light of the foregoing, AWS respectfully requests that the Court extend to August 13, 2024, AWS's deadline to file its answer to Plaintiff's SAC. Plaintiff does not oppose the request.
7. Further, the Parties jointly request that the Court modify the Parties' proposed deadline for submission of a proposed Protective Order and ESI Protocol to August 13, 2024.
WHEREFORE, the Parties respectfully request that the Court enter an order extending existing case deadlines in accordance with this Stipulated Motion.
[PROPOSED] ORDER
IT IS SO ORDERED.