Civil Local Rule 6-2(a) Stipulation — Children's Health Defense v. Facebook, Inc. (N.D. Cal.)

Date: 2020-09-09

Summary

A Civil Local Rule 6-2(a) stipulation filed September 9, 2020 as Document 24 in Children's Health Defense v. Facebook, Inc., et al., Case No. 3:20-cv-05787-SI, in the U.S. District Court for the Northern District of California. Plaintiff Children's Health Defense and defendants Facebook, Inc., Mark Zuckerberg, The Poynter Institute for Media Studies, Inc. and PolitiFact agree to extend the briefing schedule on any Rule 12 motions. The stipulation sets the plaintiff's opposition for December 21, 2020 and the defendants' replies for January 21, 2021. It states that the complaint was filed August 17, 2020 and cites the complexity of the four counts and the holidays as good cause. The four-page filing is signed by counsel for each side and includes a signature attestation and certificate of service.

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Case 3:20-cv-05787-SI Document 24 Filed 09/09/20 Page 1 of 4

1 SONAL N. MEHTA (SBN 222086) ROGER I. TEICH (SBN 147076)
Sonal.Mehta@wilmerhale.com rteich@juno.com
2 WILMER CUTLER PICKERING 290 Nevada Street
HALE AND DORR LLP San Francisco, California 94110
3 950 Page Mill Road Telephone: (415) 948-0045
Palo Alto, California 94304
4 Telephone: (650) 858-6000 ROBERT F. KENNEDY, JR.
Facsimile: (650) 858-6100 MARY HOLLAND
5 mary.holland@childrenshealthdefense.org
Attorney for Defendants Children’s Health Defense
6 FACEBOOK, INC. and 1227 North Peachtree Parkway, Suite 202
MARK ZUCKERBERG Peachtree City, GA 30269
7 Telephone: (917) 743-3868
(Subject to pro hac vice admission)
8 KEVIN L. VICK (SBN 220738)
kvick@jassyvick.com Attorneys for Plaintiff
9 JASSY VICK CAROLAN LLP CHILDREN’S HEALTH DEFENSE
800 Wilshire Blvd.
10 Suite 800
Los Angeles, California 90017
11 Telephone: (310) 870-7048
Facsimile: (310) 870-7010
12
Attorney for Defendants
13 THE POYNTER INSTITUTE FOR MEDIA
STUDIES, INC. and POLITIFACT
14

17 UNITED STATES DISTRICT COURT

18 NORTHERN DISTRICT OF CALIFORNIA
19 SAN FRANCISCO DIVISION
20 CHILDREN’S HEALTH DEFENSE,
Case No. 3:20-cv-05787-SI
21 Plaintiff,
22 CIVIL LOCAL RULE 6-2(A)
v.
STIPULATION
23 FACEBOOK, INC., ET AL.,
24 Defendants.
25

CASE NO.: 3:20-CV-05787-SI CIVIL LOCAL RULE 6-2(A) STIPULATION
Case 3:20-cv-05787-SI Document 24 Filed 09/09/20 Page 2 of 4

1 Pursuant to Civil Local Rule 6-2(a), Defendants Facebook, Inc., Mark Zuckerberg, The

2 Poynter Institute for Media Studies, Inc., and PolitiFact (“Defendants”) and Plaintiff Children’s Health

3 Defense (“Plaintiff”), by and through their respective counsel, have consented to the following

4 enlargement of time to file Plaintiff’s Opposition to any Rule 12 motion or other response to the

5 Complaint:

6 1. Plaintiff’s Opposition to any Rule 12 motions or other responses filed by Defendants

7 shall be due December 21, 2020.

8 2. Defendants’ Replies to Plaintiff’s Opposition shall be due January 21, 2021.

9 Plaintiff filed the Complaint on August 17, 2020. (Dkt. 1). Plaintiff served the Complaint on
10 Defendant Facebook, Inc. on August 19, 2020 (Dkt. 16), and attempted service on Defendants The
11 Poynter Institute for Media Studies, Inc., and PolitiFact on August 19, 2020 and August 27, 2020,
12 respectively. A summons issued to Defendant Mark Zuckerberg on August 19, 2020. (Dkt. 7).
13 Defendants’ deadline to respond to the Complaint has been enlarged once by currently-filed stipulation
14 to October 23, 2020. 1
15 Good cause exists, and the parties’ stipulated request for an enlargement of time is reasonable

16 in light of the complicated subject matter of this case, the number of issues in dispute, and the need to

17 coordinate among multiple, separately represented defendants. The Complaint includes four counts

18 invoking complex issues of constitutional and statutory law. Moreover, the Thanksgiving holiday falls

19 within the time allotted for Plaintiff to prepare its Opposition, as do the currently-scheduled case

20 management conference and related filings, and the winter holidays fall within the time allotted for

21 Defendants to prepare their replies. This stipulated request is supported by the accompanying

22 Declaration of Sonal N. Mehta.

23 Pursuant to Civil Local Rule 6-2(a), Plaintiff and Defendants hereby request that the Court

24 enter an order allowing the enlargement of time set forth above.

27
1
Defendants reserve their rights to raise any jurisdictional, service-related, or venue-related
28 challenges in response to the Complaint, and this Stipulation does not waive any such rights.
-1-
CASE NO.: 3:20-CV-05787-SI CIVIL LOCAL RULE 6-2(A) STIPULATION
Case 3:20-cv-05787-SI Document 24 Filed 09/09/20 Page 3 of 4

2 Dated: September 9, 2020 WILMER CUTLER PICKERING, HALE AND
DORR LLP
3
By: /s/ Sonal N. Mehta
4 SONAL N. MEHTA

5 Attorney for Defendants
Facebook, Inc. and Mark Zuckerberg
6

7
Dated: September 9, 2020 JASSY VICK CAROLAN LLP
8
By: /s/ Kevin L. Vick
9 KEVIN L. VICK

10 Attorney for Defendants
The Poynter Institute for Media Studies, Inc. and
11 PolitiFact

13 Dated: September 9, 2020 By: /s/ Roger I. Teich
ROGER I. TEICH
14
Attorney for Plaintiff
15 Children’s Health Defense

28
-2-
CASE NO.: 3:20-CV-05787-SI CIVIL LOCAL RULE 6-2(A) STIPULATION
Case 3:20-cv-05787-SI Document 24 Filed 09/09/20 Page 4 of 4

1 SIGNATURE ATTESTATION

2 I am the ECF User whose identification and password are being used to file the foregoing

3 Stipulation To Enlarge Time. Pursuant to Civil Local Rule 5-1(i), I hereby attest that the other

4 signatures have concurred in this filing.

5 Dated: September 9, 2020 By: /s/ Sonal N. Mehta
Sonal N. Mehta
6

9 CERTIFICATE OF SERVICE
10 I hereby certify that on September 9, 2020, I electronically filed the above document with

11 the Clerk of the Court using CM/ECF which will send electronic notification of such filing to all

12 registered counsel.

14 Dated: September 9, 2020 By: /s/ Sonal N. Mehta
Sonal N. Mehta
15

28
-3-
CASE NO.: 3:20-CV-05787-SI CIVIL LOCAL RULE 6-2(A) STIPULATION

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Original: archive.org

Civil Local Rule 6-2(a) Stipulation — Children's Health Defense v. Facebook, Inc. (N.D. Cal.)

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