Opinion
Steven T. Lowe, Esq., Kris LeFan, Esq., LOWE & ASSOCIATES, P.C., Los Angeles, CA, Hao Ni, (pro hac vice pending), NI, WANG & MASSAND, PLLC, Dallas, TX, Attorneys for Plaintiff, HALL DATA SYNC TECHNOLOGIES, LLC.
KASOWITZ, BENSON, TORRES & FRIEDMAN LLP JEFFREY J. TONEY, JONATHAN K. WALDROP, DARCY L. JONES, MARCUS A. BARBER, ROBERT P. WATKINS III, JOHN W. DOWNING, HEATHER S. KIM, Attorneys for Defendant GOOGLE INC.
DLA PIPER LLP (US), JOHN GUARAGNA, AARON WAINSCOAT, Attorneys for Defendant BOX INC.
FARELLA BRAUN + MARTEL LLP, Jeffrey M. Fisher, Deepak Gupta, Winston Liaw, Attorneys for Defendant DROPBOX INC.
STIPULATED MOTION AND [PROPOSED] ORDER FOR RELIEF FROM DEADLINE TO FILE JOINT CASE MANAGEMENT CONFERENCE STATEMENT IN RELATED ACTIONS PURSUANT TO L.R. 16-2(D)
VINCE CHHABRIA, District Judge.
The Parties in the above captioned cases jointly move under Civ. L.R. 16-2(d) for a three-day extension to the deadline to submit the Joint Case Management Conference Statement ("Joint CMC Statement") to allow additional time review and submit an agreed upon Statement.
Local Rule 16-2(d) provides that "a party... may seek relief from an obligation imposed by Fed.R.Civ.P. 16 or 26 or the Order Setting Initial Case Management Conference." In this case, the Court should exercise its discretion to permit a three-day modification to the deadline to submit the Joint CMC Statement. The Parties in these related actions have made their best effort to comply with the Court's August 12th Order (Dkt. 29 in Case No. 15-3063; Dkt. 25 in Case No. 15-3064; Dkt. 21 in Case No. 15-3065) setting August 18th as the deadline to submit the Parties' Joint CMC Statement. Since receiving notice of the deadline, the Parties have discussed the contents of the Joint CMC Statement telephonically and have also exchanged an initial draft of the Statement. Additional time is needed, however, to allow the parties as well as their in-house representatives to review the Joint CMC Statement and proposed schedule, and to allow further time for the parties to attempt to reach agreement on its contents. The extension will also save the Court time and resources reviewing issues that may otherwise be worked out between the Parties. Moreover, lead counsel for Google has a hearing scheduled before the Honorable Judge Virginia Phillips in the Central District of California on August 18th, which has made coordination on the Joint CMC Statement difficult.
In sum, the Parties in these related actions believe that there is good cause for a short three-day extension and respectfully request that the Court extend the deadline to submit the Joint CMC Statement from August 18, 2015 to August 21, 2015. No other deadline will be affected by this extension (including the Case Management Conference itself).
IT IS HEREBY STIPULATED AND AGREED, by and among the parties and their respective counsel of record and with the permission of the Court, that deadline to submit the Parties Initial Case Management Statement in this action shall be continued to Friday, August 21, 2015.
I hereby attest pursuant to L.R. 5.1(i)(3) that concurrence in the electronic filing of this document has been obtained from the other signatories.
[PROPOSED] ORDER
The Court having considered the stipulation of the parties, orders as follows:
• The parties shall file a Joint Case Management Statement on or before Friday, August 21, 2015.
PURSUANT TO THE PARTIES' STIPULATION, IT IS SO ORDERED.