The opinion of the court was delivered by: Honorable Edward M. Chen United States District Judge
Steve W. Berman (Pro Hac Vice) RODGER R. COLE (CSB No. 178865) HAGENS BERMAN SOBOL SHAPIRO LLP firstname.lastname@example.org 2 1918 Eighth Avenue, Suite 3300 MOLLY R. MELCHER Seattle, WA 98101 (CSB No. 272950) 3 Telephone: (206) 623-7292 email@example.com Facsimile: (206) 623-0594 FENWICK & WEST LLP 4 firstname.lastname@example.org Silicon Valley Center 801 California Street Bruce L. Simon (SBN 96241) Mountain View, CA 94041 PEARSON SIMON WARSHAW & PENNY, LLP Telephone: 650.988.8500 6 44 Montgomery Street, Suite 2450 Facsimile: 650.938.5200 San Francisco, CA 94104 7 Telephone: (415) 433-9000 TYLER G. NEWBY (CSB No. 205790) Facsimile: (415) 433-9008 email@example.com 8 firstname.lastname@example.org JENNIFER J. JOHNSON (CSB No. 252897) Plaintiffs' Interim Co-Lead Counsel email@example.com FENWICK & WEST LLP [Additional Counsel listed on 555 California Street, 12th Floor Signature Page] San Francisco, CA 94104 11 Telephone: 415.875.2300 Facsimile: 415.281.1350 Attorneys for Defendant Carrier IQ, Inc.
STIPULATION AND [PROPOSED] 20 ORDER FOR CONTINUANCE OF
[This Document Relates to All Cases] TIME FOR PLAINTIFFS TO FILE A STIPULATION REGARDING ENTRY OF A PROTECTIVE ORDER STIPULATION
This Stipulation and [Proposed] Order is entered into by and between Plaintiffs' Interim 26 Co-Lead Counsel and Defendants' counsel (collectively, the "Parties") as follows:
WHEREAS, the deadline for Plaintiffs to file a stipulation regarding the entry of a protective order was August 13, 2012;
WHEREAS, on August 10, 2012, the Parties filed a stipulation and [proposed] order to 2 continue the deadline for Plaintiffs to file a stipulation regarding the protective order until 14 days 3 after the filing of the consolidated, amended complaint on August 27, 2012 (Dkt. No. 105);
WHEREAS, on August 14, 2012, this Court granted the stipulation (Dkt. No. 106);
WHEREAS, the Parties have met and conferred in good faith regarding the terms of a 6 stipulated protective order and believe that an additional week will allow the parties to meet and 7 confer further and to resolve or substantially reduce the remaining items in dispute; 8
NOW THEREFORE, the Parties, by and through their respective counsel of record, 9 hereby stipulate, subject to Court approval, as follows:
The deadline for Plaintiffs to file a stipulation regarding the entry of a protective order 11 currently set for September 10, 2012 is continued to September 17, 2012. 12
ATTESTATION PURSUANT TO GENERAL ORDER 45
I, Molly R. Melcher, am the ECF User whose identification and password are being used 3 to file this STIPULATION AND [PROPOSED] ORDER FOR CONTINUANCE OF TIME 4 FOR PLAINTIFFS TO FILE A STIPULATION REGARDING ENTRY OF A PROTECTIVE ORDER. In compliance with General Order 45.X.B, I hereby attest that all 6 signatories have concurred in this filing.
7 Dated: September 10, 2012 /s/ Molly R. Melcher Molly R. Melcher 5 8 9 10 [PROPOSED] ORDER 11 ES DIST Pursuant to ...