Filed: Jul. 18, 2019
Latest Update: Jul. 18, 2019
Summary: STIPULATED REQUEST FOR ORDER CHANGING TIME AND ORDER [CIVIL LOCAL RULE 6-2] HAYWOOD S. GILLIAM, JR. , District Judge . Plaintiff Synchronoss Technologies, Inc., ("Synchronoss") and Defendant Dropbox, Inc., ("Dropbox") (collectively, the "Parties") by and through their respective counsel, and subject to the Court's approval, stipulate as follows: WHEREAS, on July 3, 2019, Dropbox filed its Motion for Attorney's Fees (ECF 436) and Bill of Costs (ECF 434); and WHEREAS, in light of the Jul
Summary: STIPULATED REQUEST FOR ORDER CHANGING TIME AND ORDER [CIVIL LOCAL RULE 6-2] HAYWOOD S. GILLIAM, JR. , District Judge . Plaintiff Synchronoss Technologies, Inc., ("Synchronoss") and Defendant Dropbox, Inc., ("Dropbox") (collectively, the "Parties") by and through their respective counsel, and subject to the Court's approval, stipulate as follows: WHEREAS, on July 3, 2019, Dropbox filed its Motion for Attorney's Fees (ECF 436) and Bill of Costs (ECF 434); and WHEREAS, in light of the July..
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STIPULATED REQUEST FOR ORDER CHANGING TIME AND ORDER
[CIVIL LOCAL RULE 6-2]
HAYWOOD S. GILLIAM, JR., District Judge.
Plaintiff Synchronoss Technologies, Inc., ("Synchronoss") and Defendant Dropbox, Inc., ("Dropbox") (collectively, the "Parties") by and through their respective counsel, and subject to the Court's approval, stipulate as follows:
WHEREAS, on July 3, 2019, Dropbox filed its Motion for Attorney's Fees (ECF 436) and Bill of Costs (ECF 434); and
WHEREAS, in light of the July 4 holiday and conflicting deadlines facing counsel for Synchronoss, there is good cause to extend the deadlines for Synchronoss' Opposition to Dropbox's Motion for Attorney's Fees (ECF 436) and Objections to Bill of Costs by two days, from July 17, 2019 to and including July 19, 2019, and to extend the deadlines for Dropbox's Reply to Synchronoss' Opposition to Dropbox's Motion for Attorney's Fees (Declaration of Sarah S. Eskandari in support of The Parties' Stipulated Request for Order Changing Time, "Eskandari Decl.," ¶ 3); and
WHEREAS, on July 16 and 17, 2019, the Parties met and conferred via e-mail to discuss the need for approaching the Court to request a brief extension of time for the deadline for Synchronoss' Opposition to Dropbox's Motion for Attorney's Fees (ECF 436) and Objections to Bill of Costs (ECF 434) by two days, and to extend the deadline for Dropbox's Reply to Synchronoss' Opposition to Dropbox's Motion for Attorney's Fees by two business days, to and including July 30, 2019; (Eskandari Decl., ¶ 4); and
WHEREAS, the Parties respectfully request that the Court extend the deadlines for Synchronoss' Opposition to Dropbox's Motion for Attorney's Fees (ECF 436) and Objections to Bill of Costs (ECF 434) by two days, from July 17, 2019 to and including July 19, 2019, and extend the deadline for Dropbox's Reply to Synchronoss' Opposition to Dropbox's Motion for Attorney's Fees by two business days, to and including July 30, 2019; and
WHEREAS, there have been nine prior time modifications in this case: (1) when the Court granted Synchronoss' motion for an extension of time to respond to Dropbox's original February 5, 2016 motion to dismiss (ECF 71); (2) when the Court granted the Parties' Stipulated Request for an extension of time for Dropbox to file its reply in support of the Motion to Dismiss (ECF 90); (3) when the Court granted the Parties' stipulated request for an extension of time to submit their ESI Stipulation and Protective Order (ECF 123); (4) when the Court granted the Parties' Stipulated Request to Change the Deadline for Document Production (ECF 187); (5) when the Court granted the Parties' Stipulated Request to Complete Currently Noticed Depositions Beyond The Close Of Fact Discovery (ECF 224); (6) when the Court granted the Parties' Stipulated Request to extend the deadlines to complete currently noticed fact depositions and to serve expert disclosures and reports (ECF 232); (7) when the Court granted the Parties' Stipulated Request to extend further the deadlines to complete currently noticed fact depositions and to serve expert disclosures and reports (ECF 244); and (8) when the Court granted the Parties' Stipulated Request to complete currently noticed expert depositions beyond the close of expert discovery (ECF 291); and (9) when the Court granted the Parties' Stipulated Request to reschedule the hearing date for dispositive and Daubert motions (ECF 342). (Eskandari Decl., ¶ 5.)
WHEREAS, the Parties' request will have no impact on the case schedule, as the only pending item is the hearing for Dropbox's Motion for Attorney's Fees, which is noticed for November 14, 2019. (Eskandari Decl., ¶ 6.)
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, BY AND BETWEEN THE PARTIES THROUGH THEIR RESPECTIVE COUNSEL, THAT, the Parties respectfully request that the Court: (1) extend the deadlines for Synchronoss' Opposition to Dropbox's Motion for Attorney's Fees (ECF 436) and Objections to Bill of Costs (ECF 434) by two days, from July 17, 2019 to and including July 19, 2019, and (2) extend the deadline for Dropbox's Reply to Synchronoss' Opposition to Dropbox's Motion for Attorney's Fees by two business days, to and including July 30, 2019.
Dated this 17th day of July, 2019
/s/Sarah S. Eskandari /s/Jonathan A. Patchen
___________________________________ _______________________
SARAH S. ESKANDARI (SBN 271541) STEPHEN E. TAYLOR (SBN 058452)
JENNIFER D. BENNETT (SBN 235196) JONATHAN A. PATCHEN (SBN 237346)
DENTONS US LLP
One Market Plaza, KARAN S. DHADIALLA (SBN 296313)
Spear Tower, 24th Floor TAYLOR & PATCHEN, LLP
San Francisco, CA 94105 One Ferry Building, Suite 355
Telephone: (415) 267-4000 San Francisco, CA 94111
Facsimile: (415) 267-4198 Telephone: (415) 788-8200
Email: sarah.eskandari@dentons.com Facsimile: (415) 788-8208
Email: jennifer.bennett@dentons.com E-mail: staylor@taylorpatchen.com
E-mail: jpatchen@taylorpatchen.com
MARK L. HOGGE (Pro Hac Vice) E-mail: kdhadialla@taylorpatchen.com
KIRK R. RUTHENBERG (Pro Hac Vice)
NICHOLAS H. JACKSON (SBN 269976)
KEVIN GREENLEAF (SBN 256896) THOMAS H. L. SELBY (pro hac vice)
RAJESH NORONHA (Pro Hac Vice) DAVID M. KRINSKY (pro hac vice)
ADAM D. HARBER (pro hac vice)
DENTONS US LLP CHRISTOPHER J. MANDERNACH (pro
1900 K Street, N.W. hac vice)
Washington, DC 20006 SARAH L. O'CONNOR (pro hac vice)
Telephone: (202) 408-6400 D. SHAYON GHOSH (SBN 313628)
Facsimile: (202) 408-6399 WILLIAMS & CONNOLLY LLP
Email: mark.hogge@dentons.com
Email: kirk.ruthenberg@dentons.com 725 Twelfth Street, N.W.
Email: nicholas.jackson@dentons.com Washington, D.C. 20005
Email: kevin.greenleaf@dentons.com Telephone: (202) 434-5000
Email: rajesh.noronha@dentons.com Facsimile: (202) 434-5029
E-mail: tselby@wc.com
E-mail: dkrinsky@wc.com
Attorneys for Plaintiff E-mail: aharber@wc.com
Synchronoss Technologies, Inc. E-mail: cmandernach@wc.com
E-mail: soconnor@wc.com
E-mail: sghosh@wc.com
Attorneys for Defendant
Dropbox, Inc.
ORDER
THIS MATTER, came before the Court on a Stipulated Request for Order Changing Time by Plaintiff Synchronoss Technologies, Inc. and Defendant Dropbox, Inc., (collectively, the "Parties"). The Court, having reviewed and considered the submitted papers in this matter and all relevant factual statements therein, hereby GRANTS the Parties' Stipulated Request to extend the deadlines for Synchronoss' Opposition to Dropbox's Motion for Attorney's Fees (ECF 436) and Objections to Bill of Costs (ECF 434) by two days, from July 17, 2019 to and including July 19, 2019, and to extend the deadline for Dropbox's Reply to Synchronoss' Opposition to Dropbox's Motion for Attorney's Fees to and including July 30, 2019.
IT IS SO ORDERED.
