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Rowena Silvera and andrew v. Carrier Iq

December 29, 2011

ROWENA SILVERA AND ANDREW
SANDERS, INDIVIDUALLY, AND ON BEHALF OF ALL SIMILARLY SITUATED PERSONS,
SAMSUNG ELECTRONICS AMERICA, INC. PLAINTIFFS,
v.
CARRIER IQ, INC., SAMSUNG ELECTRONICS AMERICA, INC., HTC AMERICA INC., AT&T, INC., SPRINT COMMUNICATIONS COMPAN Y, L.P., JOHN DOE MANUFACTURERS (1-10), JOHN DOE CARRIERS (1-10),
DEFENDANTS.



The opinion of the court was delivered by: Honorable Edward J. Davila United States District Judge

STEVEN J. SKIKOS (SBN 148110) sskikos@skikoscrawford.com 2 MARK G. CRAWFORD (SBN 136501) mcrawford@skikoscrawford.com 3 SKIKOS, CRAWFORD, SKIKOS & JOSEPH LLP 4 625 Market Street, 11th Floor San Francisco, CA 94105 5 Telephone: (415) 546-7300 Facsimile: (415) 546-7301 6 Attorneys for Plaintiffs 7 LANCE A. ETCHEVERRY (SBN 199916) 8 lance.etcheverry@skadden.com SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP 9 300 S. Grand Avenue, Suite 3400 Los Angeles, California 90071-3144 Telephone: (213) 687-5000 Facsimile: (213) 687-5600 11 Attorneys for Defendant 12 SAMSUNG ELECTRONICS AMERICA, INC. 13

Additional counsel listed on signature page 14

STIPULATION RE: EXTENSION OF TIME FOR DEFENDANT TO RESPOND TO COMPLAINT AND [PROPOSED] ORDER EXTENDING TIME TO RESPOND TO COMPLAINT

3 other laws by the defendants in this case; 4

5 throughout the United States by plaintiffs purporting to bring class actions on behalf of cellular 6 telephone and other device users on whose devices software made by defendant Carrier IQ, Inc. is 7 or has been embedded (collectively, including the above-captioned matter, the "CIQ cases"); 8

9 transfer the CIQ cases to this jurisdiction for coordinated and consolidated pretrial proceedings 10 pursuant to 28 U.S.C. Sec. 1407, responses to the motion supporting coordination or consolidation 11 have been filed, and plaintiffs and defendants anticipate that additional responses will be filed; 12

13 complaints in the CIQ cases; 14

15 an orderly schedule for any response to the pleadings in the CIQ cases would be more efficient for 16 the parties and for the Court;

WHEREAS the above-referenced plaintiffs filed the above-captioned case;

WHEREAS the above-referenced plaintiffs allege violations of the Federal Wiretap Act and

WHEREAS over 50 other complaints have been filed to-date in federal district courts

WHEREAS, a motion is pending before the Judicial Panel on Multidistrict Litigation to

WHEREAS plaintiffs anticipate the possibility of one or more consolidated amended

WHEREAS plaintiffs and defendant Samsung Electronics America, ...


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