The opinion of the court was delivered by: The Honorable Jeremy Fogel
KEITH E. EGGLETON, State Bar No. 159842 Email: firstname.lastname@example.org RODNEY G. STRICKLAND, State Bar No. 161934 Email: email@example.com DALE BISH, State Bar No. 235390 Email: firstname.lastname@example.org 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.
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 ...