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Jeff Milans, Individually and On Behalf of All v. Netflix

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION


February 24, 2011

JEFF MILANS, INDIVIDUALLY AND ON BEHALF OF ALL
JF OTHERS SIMILARLY SITUATED,
PLAINTIFF,
v.
NETFLIX, INC., A DELAWARE CORPORATION
DEFENDANT,

The opinion of the court was delivered by: The Honorable Jeremy Fogel

KEITH E. EGGLETON, State Bar No. 159842 Email: keggleton@wsgr.com RODNEY G. STRICKLAND, State Bar No. 161934 Email: rstrickland@wsgr.com DALE BISH, State Bar No. 235390 Email: dbish@wsgr.com WILSON SONSINI GOODRICH & ROSATI Professional Corporation 650 Page Mill Road Palo Alto, CA 94304-1050 Telephone: (650) 493-9300 Facsimile: (650) 565-5100 Attorneys for Defendant NETFLIX, INC.

STIPULATION AND [PROPOSED] ) ORDER REGARDING DEFENDANT'S RESPONSE TO THE COMPLAINT

WHEREAS, Plaintiff filed and served a class action complaint alleging certain claims against defendant Netflix, Inc. ("Netflix") for alleged violations of certain privacy and consumer 24 24 protection statutes;

WHEREAS, Netflix has requested and Plaintiff has agreed to an extension of time for Netflix to respond to the complaint; and

WHEREAS, this proposed extension would have no effect on the current schedule for thecase;

NOW THEREFORE, IT IS HEREBY STIPULATED that: 2

1. Netflix shall respond to the complaint no later than April 1, 2011.

2. This stipulation is without prejudice to the rights, claims, or defenses of any party,

4 and shall not be used by Netflix as evidence of, or to support any argument that, Plaintiff has not 5 timely pursued his claims or has not been diligent. 6 7

/s/ Rodney G. Strickland, Jr. 8 Rodney G. Strickland, Jr. WILSON SONSINI GOODRICH & ROSATI Attorneys for Defendant NETFLIX, INC. Dated: February 24, 2011 /s/ Sean Reis Sean Reis EDELSON McGUIRE LLP Attorneys for Plaintiff

Defendant shall respond to the complaint no later than April 1, 2011.

Dated: 3/3/11

I, Rodney G. Strickland, Jr., am the ECF User whose identification and password are being used to file the Stipulation And [Proposed] Order Regarding Defendant's Response to the Complaint. I hereby attest Sean Reis has concurred in this filing.

Dated: February 24, 2011 Rodney G. Strickland, Jr. Rodney G. Strickland, Jr. WILSON SONSINI GOODRICH & ROSATI Attorneys for Defendant NETFLIX, INC.

20110224

© 1992-2011 VersusLaw Inc.



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