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 January 9, 2018, the Court issued an Order Setting the Case Schedule that set a May 3, 2019 date for the Parties to file dispositive and Daubert motions, and an August 12, 2019 date for the commencement of jury trial (ECF 173); and

WHEREAS, the Parties have filed certain dispositive and Daubert motions, which, based on the May 3, 2019 filing date and the Local Rules, will be fully briefed by May 24, 2019; and

WHEREAS, the Parties noticed hearings for those motions for the first available hearing date according to the Court's publicly posted calendar, August 29, 2019, which falls after the August 12 trial date (See Declaration of D. Shayon Ghosh ("Ghosh Decl."), ¶ 4); and

WHEREAS, on April 30 and May 2, 2019, the Parties met and conferred via e-mail to discuss the need for approaching the Court to request an earlier hearing date on any dispositive and Daubert motions (Ghosh Decl., ¶ 5); and

WHEREAS, the Parties believe there is good cause to shorten time for the hearing on the Parties' dispositive and Daubert motions, so that the Court may hear argument on any such motions before the commencement of trial (Ghosh Decl., ¶ 6); and

WHEREAS, the Parties respectfully request that the Court hear the Parties' dispositive and Daubert motions at the Court's earliest convenience in June or July of 2019 so that they may be decided sufficiently in advance of trial (Ghosh Decl., ¶ 7); and

WHEREAS, there have been eight 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 91); (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

WHEREAS, the Parties' request will have no impact on the schedule, as the remaining deadlines in the Scheduling Order will be unaffected (Ghosh Decl, ¶ 9),

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 schedule a hearing date for dispositive and Daubert motions at its earliest convenience in June or July of 2019.

FILER'S ATTESTATION:

I, Karan S. Dhadialla, am the ECF user whose ID and password are being used to file the above STIPULATED REQUEST FOR ORDER CHANGING TIME [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.

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 and sets a hearing date for the Parties' dispositive and Daubert motions on June 7, 2019, at 3:00 p.m.

IT IS SO ORDERED.