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CASE NO.: 3:20-CV-05787-SI
STIPULATION TO ENLARGE TIME TO RESPOND TO
COMPLAINT
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SONAL N. MEHTA (SBN 222086)
Sonal.Mehta@wilmerhale.com
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: (650) 858-6000
Facsimile: (650) 858-6100
Attorney for Defendants
FACEBOOK, INC. and
MARK ZUCKERBERG
KEVIN L. VICK (SBN 220738)
kvick@jassyvick.com
JASSY VICK CAROLAN LLP
800 Wilshire Blvd.
Suite 800
Los Angeles, California 90017
Telephone: (310) 870-7048
Facsimile: (310) 870-7010
Attorney for Defendants
THE POYNTER INSTITUTE FOR MEDIA
STUDIES, INC. and POLITIFACT
ROGER I. TEICH (SBN 147076)
rteich@juno.com
290 Nevada Street
San Francisco, California 94110
Telephone: (415) 948-0045
ROBERT F. KENNEDY, JR.
MARY HOLLAND
mary.holland@childrenshealthdefense.org
Children’s Health Defense
1227 North Peachtree Parkway, Suite 202
Peachtree City, GA 30269
Telephone: (917) 743-3868
(Subject to pro hac vice admission)
Attorneys for Plaintiff
CHILDREN’S HEALTH DEFENSE
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
CHILDREN’S HEALTH DEFENSE,
Plaintiff,
v.
FACEBOOK, INC., ET AL.,
Defendants.
Case No. 3:20-cv-05787-SI
STIPULATION TO ENLARGE TIME
TO RESPOND TO COMPLAINT PER
L.R. 6-1(A)
Case 3:20-cv-05787-SI Document 23 Filed 09/09/20 Page 1 of 4
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CASE NO.: 3:20-CV-05787-SI
STIPULATION TO ENLARGE TIME TO RESPOND TO COMPLAINT
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Pursuant to Civil Local Rule 6-1(a), Defendants Facebook, Inc., Mark Zuckerberg, PolitiFact,
and The Poynter Institute for Media Studies, Inc. (“Defendants”) and Plaintiff Children’s Health
Defense (“Plaintiff”), by and through their respective counsel, hereby stipulate as follows:
WHEREAS, Plaintiff filed the Complaint (Dkt. 1) on August 17, 2020;
WHEREAS, Plaintiff served the Complaint on Defendant Facebook, Inc. on August 19, 2020.
(Dkt. 16). A summons also issued to Mark Zuckerberg on August 19, 2020. (Dkt. 7). Service was
also attempted on The Poynter Institute for Media Studies on August 19, 2020, and on PolitiFact on
August 27, 2020.1
WHEREAS, Defendant Facebook, Inc.’s response to the Complaint is currently due September
9, 2020. Assuming Mr. Zuckerberg was served the same day as Facebook, and barring any service
defects, Defendant Mr. Zuckerberg’s response to the Complaint would also be due on September 9,
2020. Barring any service defects, Defendants The Poynter Institute for Media Studies, Inc.’s and
PolitiFact’s response to the Complaint would be due on September 9, 2020 and September 17, 2020.
WHEREAS, these Defendants only recently retained present counsel to represent them in this
action.
WHEREAS, Defendants have asked for, and Plaintiff has consented to, an extension of time
for Defendants to answer, move, or otherwise respond to the Complaint, up to and including October
23, 2020. This represents a 44-day extension with respect to Defendants Facebook, Inc., Mark
Zuckerberg, and The Poynter Institute for Media Studies, Inc., and a 36-day extension with respect to
Defendant PolitiFact.
WHEREAS, the parties also wish to align the response dates and briefing schedule for
Defendants Facebook, Inc., Mark Zuckerberg, The Poynter Institute for Media Studies, Inc., and
PolitiFact.
WHEREAS, this is the first extension of time in this matter and will not affect any other date
already set by Court order.
1 Defendants reserve their rights to raise any jurisdictional, service-related, or venue-related
challenges in response to the Complaint, and this Stipulation does not waive any such rights.
Case 3:20-cv-05787-SI Document 23 Filed 09/09/20 Page 2 of 4
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CASE NO.: 3:20-CV-05787-SI
STIPULATION TO ENLARGE TIME TO RESPOND TO COMPLAINT
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IT IS HEREBY STIPULATED AND AGREED by Plaintiff and Defendants, pursuant to
Civil Local Rule 6-1(a), to enlarge the time for Defendants to answer, move, or otherwise respond
to the Complaint up to and including October 23, 2020.
Dated: September 9, 2020
Dated: September 9, 2020
WILMER CUTLER PICKERING, HALE AND
DORR LLP
By:
/s/ Sonal N. Mehta
SONAL N. MEHTA
Attorney for Defendants
Facebook, Inc. and Mark Zuckerberg
JASSY VICK CAROLAN LLP
By: /s/ Kevin L. Vick
KEVIN L. VICK
Attorney for Defendants
The Poynter Institute for Media Studies, Inc, and
PolitiFact
Dated: September 9, 2020
By:
/s/ Roger Ian Teich
ROGER IAN TEICH
Attorney for Plaintiff
Children’s Health Defense
Case 3:20-cv-05787-SI Document 23 Filed 09/09/20 Page 3 of 4
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STIPULATION TO ENLARGE TIME TO RESPOND TO COMPLAINT
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SIGNATURE ATTESTATION
I am the ECF User whose identification and password are being used to file the foregoing
Stipulation To Enlarge Time To Respond To Complaint. Pursuant to Civil Local Rule 5-1(i), I
hereby attest that the other signatures have concurred in this filing.
CERTIFICATE OF SERVICE
I hereby certify that on September 9, 2020, I electronically filed the above document with
the Clerk of the Court using CM/ECF which will send electronic notification of such filing to all
registered counsel.
Dated: September 9, 2020
By:
/s/ Sonal N. Mehta
Sonal N. Mehta
Dated: September 9, 2020
By:
/s/ Sonal N. Mehta
Sonal N. Mehta
Case 3:20-cv-05787-SI Document 23 Filed 09/09/20 Page 4 of 4