Stipulation and OrderCal. Super. - 6th Dist.November 23, 20200n 9/14/2021 1:51 PM Reviewed §¥LAU Nakamoto Envelone: 79690.77 EFS‘°2°ATTORNEY OR PARTY WITHOUT ATTORNEY: STATEéAR NO: I I NAME Manny Starr; Theodore Tang (313294) FIRM NAME FRONTIER LAW CENTER STREET ADDRESS: 23901 Calabasas Road, Suite 2074 CITY: Calabasas STATE: CA ZIP CODE; 91302 TELEPHONE No. (818) 914-3433 FAx No; (818) 914-3433 E-MAIL ADDRESS manny@frontierlawcenter.com; theodore@frontierlawcenter.com ATTORNEY Fomname): Plaintiff, J DOE SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F SANTA CLARA STREET ADDRESS: 191 N. First Street MAILING ADDRESS: same CITY ANDZIP CODE; San Jose, 951 13 BRANCH NAME: Downtown San Jose Fo'R' COURT use ONLY PLAINTIFF/PETITIONER: J DOE \ DEFENDANT/RESPONDENTI ROKU, INC. and LONG-Jl LIN OTHER: L CASE NUMBER: 20CV37394O JUDICiAL OFFICER: PROPOSED ORDER (COVER SHEET) DEPT: order in PDF format are filed. FOE This cover sheet is to be used to electronically file and submit to the court a proposed order. The proposed order sent electronically to the court must be in PDF format and must be attached to this cover sheet. In addition, a version of the proposed order in an editable word-processing format must be sent to the court at the same time as this cover sheet and the attached proposed 1. Name of the party submitting the proposed order: Plaintiff, J Doe 2. Title of the proposed order: Stipulation to Extend Time to Amend and [Proposed] Order 3. The proceeding to which the proposed order relates is: a. Description of proceeding: b. Date and time: c. Place: 4. The proposed order was served on the other parties in the case. Manny Starr ’ (TYPE 0R PRINT NAME) / (SIGNATURE 0F PARTNRAIIQBNM Form AdaptedforManda'ory Use PROPOSED ORDER (COVER SHEET) JudicialCouncilof California _ _ _ EFs.020[Rev. Febmarytzow] (Electronlc Flllng) Page 1 of 2 Cal‘ Rules of Court. rules 2.252. 3‘1312 www. courts. ca. gov EFS-020 CASE NAME: CASE NUMBER: J Doe v. Roku, et al. 200V373940 PROOF OF ELECTRONIC SERVICE PROPOSED ORDER 1. I am at least 18 years old and not a party to this action. 3‘ My residence or business address is (specify): 23901 Calabasas Road. Ste., 2074, Calabasas. CA 91302 b. My electronic service address is (specify): heather@frontierlawcenter.corn 2. I electronically served the Proposed Order (Cover Sheet) with a proposed order in PDF format attached. and a proposed order in an editable word-processing format as follows: a. On (name of person served) (If the person served is an attorney, the pan‘y or parties represented should also be stated): Attorneys for Defendants, Gregory Tennhoff, Joshua Elegant b. To (electronic service address ofperson served): tenhoffgc@cooley.com; jelefant@cooley.com c. On (date): 9/14/2021 E Electronic service of the Proposed Order (Cover Sheet) with the attached proposed order in PDF format and service of the proposed order in an editable word-processing format on additional persons are described in an attachment. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date: 9/14/2021 Heather Bourne (TYPE OR PRINT NAME OF DECLARANT) (SIG URE 6F DECLARANT) EFs.ozo[Rev, February 1. 20171 PROPOSED ORDER (COVER SHEET) "9‘2": (Electronic Filing) mei I savewsforml -| COOLEY LLP ATIDRNEYS AT LAW PALO ALTO IO 12 l3 I4 15 I6 17 l9 20 21‘ 22 23‘ 24 25 26 27 28 Howard L. Magee (State Bar No. 185199) Larry W. Lee (State Bar No. 228175) Max W. Gavron (State Bar No. 291 697) DIVERSITY LAW GROUP, A Professional Corporation 5l5 South Figueroa Street, Suite 1250 Los Angeles, California 9007] (213) 488-6555 (2| 3) 488-6554 facsimile Robert Starr (State Bar No. 183052) Theodore Tang (State Bar No. 3 l 3294) Manny Starr (State Bar No. 3 I 9778) FRONTIER LAW CENTER 2390] Calabasas Road, Suite 2074 Calabasas, California 91302 T: (818) 914-3433 F: (8| 8) 914-3433 Attorneys for Plaintiff J DOE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA J DOE, as an individual, Plaintiff, v. ROKU, INC., a Delaware corporation; LONG-Jl LIN, an individual, and DOES l through 50, inclusive, Defendants. I. STIPULATION. Case N0. 20CV3 73940 STIPULATION TO EXTEND TIME TO AMENDAND [PROPOSED] ORDER Date Action Filed: November 23, 2020 WHEREAS, Defendant Long-Ji Lin’s Demurrer to the First Amended Complaint of Plaintiff] Doe was sustained 0n August 24, 2021; WHEREAS, On sustaining the Demurrer, the Court granted Plaintiff 20 days leave t0 240576886 v1 STIPULATION TO EXTEND TIME TO AMEND AND [PROPOSED] ORDER ----------------- Filed September 23, 2021 County of Santa Clara Superior Court of CA Clerk of the Court 20CV373940 By: rburciaga Signed: 9/23/2021 12:02 PM 1 amend; 2 WHEREAS, Plaintiff’s last day to amend the complaint therefore falls on September l4, 3 2021; and 4 WHEREAS, the parties have entered into a settlement in principal and wish to maintain 5 the status quo long enough to execute formal settlement agreements 6 IT IS HEREBY STIPULATED by and between the Parties hereto, by and through their 7 respective counsel of record, that Plaintiff shall have until October I4, 2021 to file a Second 8 Amended Complaint. 9 This Stipulation may be executed in counterparts. l l SO STIPULATED AND AGREED: 12 l3 Dated: September 13, 2021 COOLEY LLP GREGORY C. TENHOFF l4 HELEN LUU JOSHUA E. ELEFANT 15 I6 By: WW Attorneys for Defendant ROKU, INC. and LONG-Jl '7 LIN 18 19 Dated; September 14, 2021 DIVERSITY LAW GROUP HOWARD L. MAGEE 20 LARRY w. LEE 2| MAX w. GAVRON 22 FRONTIER LAW CENTER ROBERTSTARR 23 THEODORE TANG MANNY STARR 24 25 BY:W/% 26 Anomas for Plaintim DGE’ 27 28 COOLEY LLP ATmRNEVSA‘rLAw “ 2 ' “M” STIPULATION T0 EXTEND TIME T0 AMEND AND [PROPOSED] ORDER COOLEY LLP ATIORNEYS AT LAW PAID AL1D 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ORDER GOOD CAUSE APPEARING, the Court hereby approves this Stipulation. Plaintiff‘s Second Amended Complaint shall be filed no later than October 14, 2021 IT IS SO ORDERED. Dated: -3- Judge of the Santa Clara County Superior Coun STIPULATION TO EXTEND TIME TO AMEND AND IPROPOSEDI ORDER September 22, 2021 Signed: 9/22/2021 08:08 PM