STIPULATED REQUEST FOR ORDER CHANGING TIME AND ORDER

[CIVIL LOCAL RULE 6-2]

HAYWOOD S. GILLIAM, Jr., District Judge.

Defendant Funambol, Inc. ("Funambol") and Plaintiff Synchronoss Technologies, Inc. ("Synchronoss"), collectively (the "Parties"), by and through their respective counsel and subject to the Court's approval, have met and conferred and stipulate as follows:

WHEREAS, on March 15, 2017, the Court issued an Order Setting Schedule that set a March 31, 2017 deadline for the Parties to submit an ESI Stipulation and Protective Order (ECF 133).

WHEREAS, in light of the fact that, to date, the Parties continue to negotiate the ESI Stipulation and Protective Order, and given the complexity of the case, have not yet come to an agreement on the terms of such a stipulation and Protective Order, there is good cause to extend the date for the Parties to submit their ESI Order and Protective Order by two court days, from March 31, 2017, to and including April 4, 2017.

WHEREAS, there have only been three prior time modifications in this case with respect to the Case Management Conference: (1) pending the Court's decision on the administrative motion to relate the case to Funambol and Egnyte; (2) pending the Court's decision on Funambol's Motion to Dismiss in the related matter Synchronoss v. Dropbox, Case No. 16-cv-00119-HSG (ECF 52, 57) and; (3) when the Court granted the Parties' Stipulated Request to continue the date of the Case Management Conference (ECF 78). See Civil L.R. 6-2(a)(2).

WHEREAS, the Parties' requested extension will have no impact on the schedule for the case overall, as the remaining deadlines in the Scheduling Order will be unaffected; the requested two day extension will leave the Parties with three (3) weeks prior to the April 24, 2017 due date for Synchronoss' Disclosure of Asserted Claims and Infringement Contentions and accompanying document production, per Patent Local Rules 3-1 and 3-2 and the Order Setting Schedule (ECF 133); and the brief extension will not prejudice any Party.

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, BY AND BETWEEN THE PARTIES THROUGH THEIR RESPECTIVE COUNSEL, THAT subject to the Court's approval: The date for the Parties to file their ESI Stipulation and Protective Order is extended from March 31, 2017, to and including April 4, 2017.

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.

FILER'S ATTESTATION:

I, Sarah S. Eskandari, am the ECF user whose ID and password are being used to file the above STIPULATED REQUEST FOR ORDER CHANGING TIME AND [PROPOSED] ORDER [CIVIL LOCAL RULE 6-2]. In compliance with Civil Local Rule 5-1(i)(3), I hereby attest that each listed counsel above has concurred in this filing.