Alpha Inv. LLC
v.
Zynga Inc.

This case is not covered by Casetext's citator
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIAApr 2, 2012
CASE NO. CV 11-3500-JSW (N.D. Cal. Apr. 2, 2012)

CASE NO. CV 11-3500-JSW

04-02-2012

ALPHA INVESTMENT, LLC, Plaintiff, v. ZYNGA INC. and ANDREW TRADER, Defendants.

VICK LAW-GROUP, APC By Scott Vick (Bar No. 171944) Jessica Han (Bar No. 228859) Lital Gilboa (Bar No. 263372) Attorneys for Defendant Andrew Trader COOLEY LLP By Stephen C. Neal (Bar No. 170085) (nealsc(2),cooley.com) John C. Dwver (Bar No. 136533) (dwyeri c(2),cooley.com) Jeffrey M. Kaban (Bar No. 235743) Attorneys for Defendant Zynga Inc. ALLEN & OVERY LLP By Jacob S. Pultman (admitted Attorneys for Plaintiff Alpha Investment, LLC


CRONE HAWXHURST


Gerald E. Hawxhurst (Bar No. 220327)


Joshua P. Gelbart (Bar No. 274021)


10880 Wilshire Blvd., Suite 1150


Los Angeles, California 90024


Attorneys for Plaintiff


Alpha Investment, LLC


ALLEN & OVERY LLP


Jacob S. Pultman (Admitted Pro Hac Vice)


Molly C. Spieczny (Admitted Pro Hac Vice)


Attorneys for Plaintiff


Alpha Investment, LLC


[Additional counsel information listed on


signature page]


STIPULATED REQUEST FOR ORDER CHANGING TIME


[PROPOSED ORDER SUBMITTED HEREWITH]

WHEREAS, on August 1, 2011, the Court entered an Order scheduling the Case Management Conference for October 28, 2011;

WHEREAS, motions to dismiss and a motion to intervene (the "Motions") were filed by Defendants Zynga Inc. and Andrew Trader ("Defendants") on August 5, 2011 and noticed for oral argument on November 4, 2011;

WHEREAS, on September 14, 2011, the parties stipulated and agreed that, with the consent of the Court, the Case Management Conference originally set for October 28, 2011 should be adjourned until November 4, 2011, so as to coincide with oral argument on the Motions;

WHEREAS, on September 15, 2011, the Court entered an Order scheduling the Case Management Conference for November 4, 2011, immediately following oral argument on the Motions;

WHEREAS, on October 27, 2011, an Amended Clerk's Notice was entered in this action rescheduling for December 16, 2011 the oral argument on the Motions and the Case Management Conference that had been previously scheduled for November 4, 2011;

WHEREAS, on November 14, 2011, the parties stipulated and agreed that, with the consent of the Court, the oral argument on the Motions and the Case Management Conference set for December 16, 2011 should be adjourned until February 10, 2012, the earliest date available after December 16, 2011 on which oral argument on the Motions and the Case Management Conference could be held, in order to accommodate the schedule of lead counsel for Defendant Zynga Inc.;

WHEREAS, on November 15, 2011, the Court entered an Order scheduling oral argument on the Motions and the Case Management Conference for February 10, 2010;

WHEREAS, on February 6, 2012, the Court entered an Order requiring further briefing and continuing the hearing on the Motions to March 16, 2012 and the Case Management Conference to March 30, 2012;

WHEREAS, on March 12, 2012, the Court entered an Order granting Defendants' motions to dismiss, denying Defendant Trader's motion to intervene as moot, granting Plaintiff leave to amend within 20 days or by April 2, 2012, directing Defendants to answer or move to dismiss within 20 days of service of the amended complaint; and vacating the Case Management Conference to be reset, if necessary, at a later date;

WHEREAS, an amended complaint in this action is being filed on April 2, 2012; WHEREAS, due to scheduling conflicts, lead counsel for Defendant Andrew Trader is unavailable between April 29, 2012 and May 13, 2012, and again between May 21, 2012 and May 25, 2012; and

WHEREAS, the parties seek the prompt resolution of this action;

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between the parties to this action, through the undersigned counsel of record, pursuant to Rules 6.1(b) and 6.2(a) of the Civil Local Rules of the United States District Court for the Northern District of California, as follows:

1. Subject to the consent of the Court, Defendants shall answer or move to dismiss the amended complaint by May 2, 2012;

2. Subject to the consent of the Court, if Defendants move to dismiss the amended complaint, Plaintiff shall file oppositions to Defendants' motions to dismiss by May 18, 2012;

3. Subject to the consent of the Court, Defendants shall file replies to Plaintiff's oppositions by May 30, 2012;

4. Subject to the consent of the Court, oral argument on the motions to dismiss the amended complaint and the Case Management Conference shall be set for June 15, 2012.

5. The parties to this action enter this stipulation without prejudice to any parties' rights with respect to discovery, including but not limited to a party's right to serve, object to, move to compel, quash or stay discovery, or to seek further relief from the Court as appropriate.

VICK LAW-GROUP, APC

By Scott Vick (Bar No. 171944)


Jessica Han (Bar No. 228859)


Lital Gilboa (Bar No. 263372)


Attorneys for Defendant Andrew Trader

COOLEY LLP

By Stephen C. Neal (Bar No. 170085)


(nealsc(2),cooley.com)


John C. Dwver (Bar No. 136533)


(dwyeri c(2),cooley.com)


Jeffrey M. Kaban (Bar No. 235743)


Attorneys for Defendant


Zynga Inc.


ALLEN & OVERY LLP

By Jacob S. Pultman (admitted pro hac vice)


Attorneys for Plaintiff Alpha Investment, LLC


VICK LAW-GROUP, APC

By Scott Vick (Bar No. 171944)


Jessica Han (Bar No. 228859)


Lital Gilboa (Bar No. 263372)


Attorneys for Defendant Andrew Trader

COOLEY LLP

By Stephen C. Neal (Bar No. 170085)


(nealsc(2),cooley.com)


John C. Dwver (Bar No. 136533)


(dwyeri c(2),cooley.com)


Jeffrey M. Kaban (Bar No. 235743)


Attorneys for Defendant


Zynga Inc.


ALLEN & OVERY LLP

By Jacob S. Pultman (admitted pro hac vice)


Attorneys for Plaintiff Alpha Investment, LLC


VICK LAW-GROUP, APC

By Scott Vick (Bar No. 171944)


Jessica Han (Bar No. 228859)


Lital Gilboa (Bar No. 263372)


Attorneys for Defendant Andrew Trader

COOLEY LLP

By Stephen C. Neal (Bar No. 170085)


(nealsc(2),cooley.com)


John C. Dwver (Bar No. 136533)


(dwyeri c(2),cooley.com)


Jeffrey M. Kaban (Bar No. 235743)


Attorneys for Defendant


Zynga Inc.


ALLEN & OVERY LLP

By Jacob S. Pultman (admitted pro hac vice)


Attorneys for Plaintiff Alpha Investment, LLC


PURSUANT TO STIPULATION, IT IS SO ORDERED.
AS MODIFIED ABOVE, IT IS SO ORDERED.

________________________


HONORABLE JEFFREY S. WHITE


UNITED STATES DISTRICT JUDGE