Application and Order Extending Time

Cal. Super. - 6th Dist.January 11, 2021

21CV376033 0n 3/4/2021 1:19 PM Santa Clara - Civil Reviewed By: R. Burciaga Case #21 CV376083 CNRmociaga Denise M. Mingrone (SBN 135224)- Orrick Herrington & Sutcliffe 1000 Marsh Road Menlo Park, CA 94025 TELEPHONE No.: 650-614-7400 FAX NO- (Optional): E-MAIL ADDRESS (Optional): dmingrone@orrick.com ATTORNEY FOR (Name): Plaintiff, Synopsys, Inc. ATrORNEY 0R PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): E"velope: 5gp6491 6 FOR COURT USE ONLY SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F santa Clara STREET ADDRESS: 191 North First Street MAILING ADDRESS: CITY AND ZIP CODE: San JOSC, CA 951 13 BRANCH NAME: CIVil PLAINTIFF/PETITIONER: Synopsys, Inc. DEFENDANT/RESPONDENT: John Does 1 and 2 EX PARTE APPLICATION FOR EXTENSION OF TIME TO SERVE PLEADING AND ORDER EXTENDING TIME TO SERVE AND ORDER CONTINUING CASE MANAGEMENT CONFERENCE CASE NUMBER: 21-CV-376083 (See Cal. Rules of Court, rule 3.1207(2).) Note: This ex parte application will be considered without a personal appearance. 1. Applicant(name): is a. plaintiff b: cross-complainant c.E petitionerd: defendante: cross-defendant f.E respondent g.E other(describe): 2. The complaint or other initial pleading in this action was filed on (date): 01/1 1/2021 HEARING DATE: DEPT.: 7 TIME: 3. Applicant requests that the court grant an order extending time for service of the following pleading: a. Complaint b.E Cross-complaint c.E Petition d.E Answer or other responsive pleading e.E Other (describe): 4. Service and filing of the pleading listed in item 3 is presently required to be completed by (date): 03/12/2021 5. Previous applications, orders, or stipulations for an extension of time to serve and file in this action are: a. None b.E The following (describe all, including the length of any previous extensions): 6. Applicant requests an extension oftime to serve and file the pleading listed in item 3 on the following parties (name each): John Doe 1 and John Doe 2 Form Approvedforomiona' Use Ex PARTE APPLICATION FOR EXTENSION 0F TIME Judicial Council of California CM-ozo [Rem January 1, 20081 TO SERVE PLEADING AND ORDERS Page 1 of 2 Cal. Rules of Court, rules 3.110, 3.1200-3.1207 www.coun‘info.ca.gov Filed March 26, 2021 County of Santa Clara Superior Court of CA Clerk of the Court 21CV376083 By: raragon CM-OZO CASE NAME: CASE NUMBER: SYNOPSYS, INC. V. JOHN DOES 1 AND 2 21-CV-376083 7. The pleading has not yet been filed and served on the parties listed in item 6 for the following reasons (describe the efforts that have been made to serve the pleading and Why service has not been completed): Synopsys, Inc.'s motion for expedited discovery to serve a third-party subpoena to identify the Doe defendants was granted 0n 02/26/21 and Synopsys is promptly serving the subpoena on third-party TeamBlind to identify defendants. E Continued on Attachment 7. 8. An extension of time to serve and file the pleading should be granted for the following reasons: An extension of time to serve the complaint should be granted because Synopsys, Inc.'s motion for expedited discovery was granted 0n February 26, 2021. Synopsys Will promptly serve its third party subpoena t0 identify Doe Defendants. Synopsys must wait for the third-party's response and requests an extension t0 provide time for the third party t0 respond and for Synopsys to identify the currently unknown defendants in this case in order t0 amend the complaint t0 name and serve defendants. E Continued on Attachment 8. 9. If an extension of time is granted, filing and service on the parties listed in item 6 will be completed by (date): May 11, 2021 (60 days) 10. Notice of this application under rules 3.1200-3.1207 E has been provided as required (describe all parties or counsel to whom notice was given; the date, time, and manner of giving notice; what the parties or counsel were told and their responses; and whether opposition is expected) or is not required (state reasons): Synopsys, Inc. does not currently know the identities of the Doe Defendants and cannot provide notice until the parties are identified. E Continued on Attachment 10. 11. Number of pages attached: 2 | declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date: March 4, 2021 Denise M Mingmne > /s/ Denise M. Mingrone (TYPE OR PRINT NAME OF APPLICANT OR ATTORNEY FOR APPLICANT) (SIGNATURE OF APPLICANT OR ATTORNEY FOR APPLICANT) Order on Application is below E on a separate document. ORDER 1. The application for an order extending time to serve and file the pleading is granted E denied. 2. The pleading must be served and filed no later than (date): 3. The case management conference is msehed-u-led-te: a. Date: _ to remain as set 5/25/21 2:15 pm D-7 b. Tlme: c. Place: 4. Other orders: Signed: 3/24/2021 09:01 AM 5. A copy of this application and order must be served on all parties or their counsel that h ppeared in se. Date: March 24, 2021 JUDICIAL OFFICER CM-ozo [Rev- January 1y 20081 Ex PARTE APPLICATION FOR EXTENSION 0F TIME Paeem To SERVE PLEADING AND ORDERS 5/11/21 Christopher G. Rudy