Chd v. Facebook Et Al
- Date
- 2020-09-24
Summary
Exhibit A to Document 43-5, filed September 24, 2020 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. The exhibit is an email chain between counsel dated September 4 to September 9, 2020, followed by the draft stipulations and proposed orders discussed in it. The emails address extending the defendants' deadline to respond to the complaint to October 23, 2020, a briefing schedule for motions to dismiss, and whether to continue the November 20, 2020 case management conference. Plaintiff's counsel writes that any stipulation should commit the defendants not to apply amended Section 3.2 of Facebook's Terms of Service, effective October 1, 2020, to the plaintiff. The proposed order would set oppositions to Rule 12 motions due December 21, 2020.
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Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 1 of 18
Exhibit A
Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 2 of 18
From: rteich@juno.com
To: Mehta, Sonal
Cc: clocicero@tlolawfirm.com; kvick@jassyvick.com; mary.holland@childrenshealthdefense.org; Holtzblatt, Ari;
Jennings, Molly; Schultz, Allison
Subject: RE: CHD v. Facebook, et al.
Date: Wednesday, September 9, 2020 12:23:53 PM
Attachments: FACEBOOK - Stip & [Pro] Order re Complaint Response Date (Roger v.2) - 09-09-2020.docx
FACEBOOK - Stip & [Pro] Order re Complaint MTD Briefing Sched 2 (Roger v.2) - 09-09-2020.docx
FACEBOOK - [PRO] ORDER RE MTD BRIEFING SCHEDULE (Roger v.2) - 09-09-2020.docx
FACEBOOK - S. MEHTA DEC. STIP EXT COMPLAINT RESPONSE [Roger v.2] - 09-09-2020.docx
EXTERNAL SENDER
Sonal,
Attached, our revisions in Track Changes to the two Stipulations, [Proposed] Order,
and your declaration. You have our consent to file these pleadings only as revised.
I look forward to working with you, too. In normal times, it would still be difficult to
file jointly the same day if we receive the drafts at or after the close of business
eastern time where Children's Health Defense and its general counsel are located.
And, these are not normal times. I'm in Mendocino County right now.
We will not agree to continue the November 20, 2020 case management conference at
this time. In particular, we have concerns about ESI retention and protocols in this
case for which the Local Rules contemplate a specific meet and confer, and
stipulation.
We also believe that such stipulation should commit your clients not to apply
amended Section 3.2 of Facebook's Terms of Service (effective October 1, 2020) to
Children's Health Defense during the pendency of this litigation, for reasons we can
discuss at the ESI-meet and confer.
I look forward to discussing this matter with you at 11:30am today.
best,
Roger Teich
---------- Original Message ----------
From: "Mehta, Sonal" <Sonal.Mehta@wilmerhale.com>
To: "rteich@juno.com" <rteich@juno.com>, "clocicero@tlolawfirm.com"
<clocicero@tlolawfirm.com>
Cc: "kvick@jassyvick.com" <kvick@jassyvick.com>,
"mary.holland@childrenshealthdefense.org" <mary.holland@childrenshealthdefense.org>,
"Holtzblatt, Ari" <Ari.Holtzblatt@wilmerhale.com>, "Jennings, Molly"
<Molly.Jennings@wilmerhale.com>, "Schultz, Allison" <Allison.Schultz@wilmerhale.com>
Subject: RE: CHD v. Facebook, et al.
Date: Tue, 8 Sep 2020 22:23:12 +0000
Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 3 of 18
Roger,
Attached, please find the stipulations we discussed last Friday, extending the deadline
responses to the complaint to October 23, and setting a further briefing schedule including a
deadline of January 7, 2021, for defendants’ replies. (The local rules treat motions for
extensions of time to respond to a complaint differently from other extensions, so we have to
file two separate stipulations). We would like to get these on file today and appreciate your
confirmation that we have permission to sign for you.
Also, given that the motion(s) to dismiss won’t be fully briefed until January 2021, we have
proposed including a stipulation continuing the November 20 case management conference for
the time being.
We can join a call for 30 minutes at 11:30 am PT tomorrow. Speak with you then.
Best,
Sonal N. Mehta | WilmerHale
950 Page Mill Road
Palo Alto, CA 94304 USA
+1 650 600 5051 (t)
+1 650 858 6100 (f)
sonal.mehta@wilmerhale.com
From: rteich@juno.com <rteich@juno.com>
Sent: Friday, September 4, 2020 2:01 PM
To: clocicero@tlolawfirm.com
Cc: kvick@jassyvick.com; mary.holland@childrenshealthdefense.org; Mehta, Sonal
<Sonal.Mehta@wilmerhale.com>
Subject: RE: CHD v. Facebook, et al.
EXTERNAL SENDER
Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 4 of 18
Hi All,
This will memorialize our phone call just now in which we agreed to a
schedule in which (1) your client defendants will file responses to the
Complaint by Friday, October 23, 2020; and (2) plaintiff will file its
opposition to any motion to dismiss by Monday, December 7, 2020, subject
to plaintiff's good cause for any further extension.
For our part, this agreement assumes that Sonal will also be representing
Mark Zuckerberg individually, and that his response and plaintiff's
responsive pleading (if any) will be governed by the stipulation. Please
confirm at your early convenience.
We think it would be useful to hold another conference call next week to
discuss a few early case management issues which are likely to arise. There
is also a separate issue concerning Facebook only which we wish to take up
with Sonal , perhaps at the end of the call.
How is Wednesday, September 9, at 11:30am PT/ 2:30 pm ET for a (no more
than) 30-minute discussion?
Here is dial-in we can use --
Dial-In Number: 515-603-3171
Access Code: 1045032#
Sincerely,
Roger Teich
Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 5 of 18
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
Attorneys for Plaintiff
9 CHILDREN’S HEALTH DEFENSE
10
KEVIN L. VICK (SBN 220738)
11 kvick@jassyvick.com
JASSY VICK CAROLAN LLP
12 800 Wilshire Blvd.
Suite 800
13 Los Angeles, California 90017
Telephone: (310) 870-7048
14 Facsimile: (310) 870-7010
15 Attorney for Defendants
THE POYNTER INSTITUTE FOR MEDIA
16 STUDIES, INC. and POLITIFACT
17
UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
19
SAN FRANCISCO DIVISION
20
CHILDREN’S HEALTH DEFENSE,
21 Case No. 3:20-cv-05787-SI
Plaintiff,
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STIPULATION TO ENLARGE TIME
v.
23 TO RESPOND TO COMPLAINT PER
FACEBOOK, INC., ET AL., L.R. 6-1(A)
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Defendants.
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CASE NO.: 3:20-CV-05787-SI STIPULATION TO ENLARGE TIME TO RESPOND TO
COMPLAINT
Error! Unknown document property name.
Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 6 of 18
1 Pursuant to Civil Local Rule 6-1(a), Defendants Facebook, Inc., Mark Zuckerberg,
2 PolitiFact, and The Poynter Institute for Media Studies, Inc. (“Defendants”) and Plaintiff Children’s
3 Health Defense (“Plaintiff”), by and through their respective counsel, hereby stipulate as follows:
4 WHEREAS, Plaintiff filed the Complaint (Dkt. 1) on August 17, 2020;
5 WHEREAS, Plaintiff served the Complaint on Defendant Facebook, Inc. on August 19,
6 2020. (Dkt. 16). A summons also issued to Mark Zuckerberg on August 19, 2020 (Dkt. 7) Service
7 was also attempted on The Poynter Institute for Media Studies on August 19, 2020, and on PolitiFact
8 on August 27, 2020. .
9 WHEREAS, Defendant Facebook, Inc.’s response to the Complaint is currently due
10 September 9, 2020. Assuming Mr. Zuckerberg was served the same day as Facebook, and barring
11 any service defects, Defendant Mr. Zuckerberg’s response to the Complaint would also be due on
12 September 9, 2020. Barring any service defects, Defendants The Poynter Institute for Media
13 Studies, Inc.’s and PolitiFact’s response to the Complaint would be due on September 9, 2020 and
14 September 17, 2020.
15 WHEREAS, these defendants only recently retained present counsel to represent them in this
16 action.
17
18 WHEREAS, Defendants have asked for, and Plaintiff has consented to, an extension of time
19 for Defendants to answer, move, or otherwise respond to the Complaint, up to and including October
20 23, 2020. This represents a 44-day extension with respect to Defendants Facebook, Inc., Mark
21 Zuckerberg, and The Poynter Institute for Media Studies, Inc., and a 36-day extension with respect
22 to Defendant PolitiFact.
23 WHEREAS, the parties also wish to align the response dates and briefing schedule for
24 Defendants Facebook, Inc., Mark Zuckerberg, The Poynter Institute for Media Studies, Inc., and
25 PolitiFact.
26 WHEREAS, this is the first extension of time in this matter.
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CASE NO.: 3:20-CV-05787-SI STIPULATION TO ENLARGE TIME TO RESPOND TO COMPLAINT
Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 7 of 18
1 IT IS HEREBY STIPULATED AND AGREED by Plaintiff and Defendants, pursuant to
2 Civil Local Rule 6-1(a), to enlarge the time for Defendants to answer, move, or otherwise respond to
3 the Complaint up to and including October 23, 2020. 1
4
5 Dated: September 8, 2020 WILMER CUTLER PICKERING, HALE AND
DORR LLP
6
By: /s/ Sonal N. Mehta
7 SONAL N. MEHTA
8 Attorney for Defendants
Facebook, Inc. and Mark Zuckerberg
9
10
11 Dated: September 8, 2020 JASSY VICK CAROLAN LLP
12 By: /s/ Kevin L. Vick
KEVIN L. VICK
13
Attorney for Defendants
14 The Poynter Institute for Media Studies, Inc, and
PolitiFact
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Defendants reserve their rights to raise any jurisdictional challenges in response to the Complaint,
28 and this Stipulation does not waive any such rights.
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CASE NO.: 3:20-CV-05787-SI STIPULATION TO ENLARGE TIME TO RESPOND TO COMPLAINT
Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 8 of 18
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2 Dated: September 9, 2020 By: /s/ Roger Ian Teich
ROGER IAN TEICH
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Attorney for Plaintiff
4 Children’s Health Defense
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CASE NO.: 3:20-CV-05787-SI STIPULATION TO ENLARGE TIME TO RESPOND TO COMPLAINT
Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 9 of 18
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 To Respond To Complaint. Pursuant to Civil Local Rule 5-1(i), I
4 hereby attest that the other signatures have concurred in this filing.
5 Dated: September 8, 2020 By: /s/ Sonal N. Mehta
Sonal N. Mehta
6
7
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9 CERTIFICATE OF SERVICE
10 I hereby certify that on September 8, 2020, I electronically filed the above document with the
11 Clerk of the Court using CM/ECF which will send electronic notification of such filing to all
12 registered counsel.
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14 Dated: September 8, 2020 By: /s/ Sonal N. Mehta
Sonal N. Mehta
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CASE NO.: 3:20-CV-05787-SI STIPULATION TO ENLARGE TIME TO RESPOND TO COMPLAINT
Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 10 of 18
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
Attorneys for Plaintiff
9 CHILDREN’S HEALTH DEFENSE
10 KEVIN L. VICK (SBN 220738)
kvick@jassyvick.com
11 JASSY VICK CAROLAN LLP
800 Wilshire Blvd.
12 Suite 800
Los Angeles, California 90017
13 Telephone: (310) 870-7048
Facsimile: (310) 870-7010
14
Attorney for Defendants
15 THE POYNTER INSTITUTE FOR MEDIA
STUDIES, INC. and POLITIFACT
16
17
UNITED STATES DISTRICT COURT
18
NORTHERN DISTRICT OF CALIFORNIA
19
SAN FRANCISCO DIVISION
20
CHILDREN’S HEALTH DEFENSE,
21 Case No. 3:20-cv-05787-SI
Plaintiff,
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CIVIL LOCAL RULE 6-2(A)
v.
23 STIPULATION
FACEBOOK, INC., ET AL.,
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Defendants.
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CASE NO.: 3:20-CV-05787-SI CIVIL LOCAL RULE 6-2(A) STIPULATION
Error! Unknown document property name.
Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 11 of 18
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
3 Health Defense (“Plaintiff”), by and through their respective counsel, have consented to the
4 following enlargement of time to file Plaintiff’s Opposition to any Rule 12 motion or other response
5 to the Complaint:
6 1. Plaintiff’s Opposition to any Rule 12 motions or other response 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 3.
10 Plaintiff filed the Complaint on August 17, 2020. (Dkt. 1). Plaintiff served the Complaint on
11 Defendant Facebook, Inc. on August 19, 2020 (Dkt. 16), and attempted service on Defendants The
12 Poynter Institute for Media Studies, Inc., and PolitiFact on August 19, 2020 and August 27, 2020,
13 respectively. A summons issued to Defendant Mark Zuckerberg on August 19, 2020 (Dkt. 7).
14 Defendants’ deadline to respond to the Complaint has been enlarged once by currently-filed
15 stipulation to October 23, 2020.
16 Good cause exists, and the parties’ stipulated request for an enlargement of time is
17 reasonable in light of the complicated subject matter of this case, the number of issues in dispute,
18 and the need to coordinate among multiple, separately represented defendants. The Complaint
19 includes four counts invoking complex issues of constitutional and statutory law. Moreover, the
20 Thanksgiving holiday falls within the time allotted for Plaintiff to prepare its Opposition, as does the
21 currently-scheduled case management conference and related filings, and the winter holidays fall
22 within the time allotted for Defendants to prepare their replies. This stipulated request is supported
23 by the accompanying Declaration of Sonal N. Mehta.
24 Pursuant to Civil Local Rule 6-2(a), Plaintiff and Defendants hereby request that the Court
25 enter an order allowing the enlargement of time and continuance set forth above.
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CASE NO.: 3:20-CV-05787-SI CIVIL LOCAL RULE 6-2(A) STIPULATION
Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 12 of 18
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2 Dated: September 8, 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
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Dated: September 8, 2020 JASSY VICK CAROLAN LLP
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By: /s/ Kevin L. Vick
9 KEVIN L. VICK
10 Attorney for Defendants
The Poynter Institute for Media Studies, Inc. and
11 PolitiFact
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13 Dated: September 8, 2020 By: /s/ Roger I. Teich
ROGER I. TEICH
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Attorney for Plaintiff
15 Children’s Health Defense
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CASE NO.: 3:20-CV-05787-SI CIVIL LOCAL RULE 6-2(A) STIPULATION
Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 13 of 18
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3 SIGNATURE ATTESTATION
4 I am the ECF User whose identification and password are being used to file the foregoing
5 Stipulation To Enlarge Time To Respond To Complaint. Pursuant to Civil Local Rule 5-1(i), I
6 hereby attest that the other signatures have concurred in this filing.
7 Dated: September 8, 2020 By: /s/ Sonal N. Mehta
Sonal N. Mehta
8
9
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11 CERTIFICATE OF SERVICE
12 I hereby certify that on September 8, 2020, I electronically filed the above document with the
13 Clerk of the Court using CM/ECF which will send electronic notification of such filing to all
14 registered counsel.
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16 Dated: September 8, 2020 By: /s/ Sonal N. Mehta
Sonal N. Mehta
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CASE NO.: 3:20-CV-05787-SI CIVIL LOCAL RULE 6-2(A) STIPULATION
Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 14 of 18
1 SONAL N. MEHTA (SBN 222086)
Sonal.Mehta@wilmerhale.com
2 WILMER CUTLER PICKERING
HALE AND DORR LLP
3 950 Page Mill Road
Palo Alto, California 94304
4 Telephone: (650) 858-6000
Facsimile: (650) 858-6100
5
Attorney for Defendants
6 FACEBOOK, INC. and
MARK ZUCKERBERG
7
8
UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA
10
SAN FRANCISCO DIVISION
11
CHILDREN’S HEALTH DEFENSE,
12 Case No. 3:20-cv-05787-SI
Plaintiff,
13
DECLARATION OF SONAL N.
v.
14 MEHTA IN SUPPORT OF CIVIL
FACEBOOK, INC., ET AL., LOCAL RULE 6-2(A) STIPULATION
15
Defendants.
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CASE NO.: 3:20-CV-05787-SI DECLARATION OF SONAL N. MEHTA IN SUPPORT
OF CIVIL LOCAL RULE 6-2(A) STIPULATION
Error! Unknown document property name.
Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 15 of 18
1 I, Sonal N. Mehta, declare as follows:
2 1. I am a partner at Wilmer Cutler Pickering Hale and Dorr LLP. I represent Defendants
3 Facebook, Inc. and Mark Zuckerberg in the above-captioned action.
4 2. Defendants Facebook, Inc., Mark Zuckerberg, The Poynter Institute for Media
5 Studies, Inc. and PolitiFact have sought an enlargement of time to respond to Plaintiff’s Complaint.
6 3. Plaintiff requested, and the parties have agreed to, subject to the Court’s approval, an
7 enlargement of time for Plaintiff to respond to any Rule 12 motions or other responses filed by
8 Defendants up to and including December 21, 2020, and for Defendants to file their replies in
9 support of any Rule 12 motions to January 21, 2021.
10 4. The parties are requesting the Court allow this proposed enlargement of time because
11 of the complicated subject matter of this case, the number of issues in dispute, and the need to
12 coordinate among multiple, separately represented defendants. The Complaint includes several
13 alleged constitutional and statutory violations. This proposed schedule will allow the parties
14 adequate time to study the issues and submit briefing that will aid the Court in its resolution of any
15 Rule 12 motion.
16 5. Moreover, the Thanksgiving holiday and early case management conference fall
17 within the time allotted for Plaintiff to prepare its opposition brief, and the winter holidays fall
18 within the time allotted for Defendants to prepare their replies.
19 6. The time for Defendants to answer, move, or otherwise respond to the complaint has
20 been enlarged once by stipulation filed concurrently herewith, from September 9 to October 23,
21 2020 for Defendants Facebook, Inc., Mark Zuckerberg, and The Poynter Institute for Media Studies,
22 Inc., and from September 17 to October 23, 2020 for Defendant PolitiFact.
23
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25 I declare under penalty of perjury that the foregoing is true and correct.
26 Executed on this 8th day of September 2020 in Redwood City, California.
27
28 By: /s/ Sonal N. Mehta
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CASE NO.: 3:20-CV-05787-SI DECLARATION OF SONAL N. MEHTA IN SUPPORT
OF CIVIL LOCAL RULE 6-2(A) STIPULATION
Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 16 of 18
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CASE NO.: 5:20-CV-00363-BLF [PROPOSED] ORDER ON CIVIL LOCAL RULE 6-2(A)
STIPULATION
Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 17 of 18
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
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16
17
UNITED STATES DISTRICT COURT
18
NORTHERN DISTRICT OF CALIFORNIA
19
SAN FRANCISCO DIVISION
20
CHILDREN’S HEALTH DEFENSE,
21 Case No. 3:20-cv-05787-SI
Plaintiff,
22
[PROPOSED] ORDER ON CIVIL
v.
23 LOCAL RULE 6-2(A) STIPULATION
FACEBOOK, INC., ET AL.,
24
Defendants.
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CASE NO.: 3:20-CV-05787-SI [PROPOSED] ORDER ON CIVIL LOCAL RULE 6-2(A)
STIPULATION
Error! Unknown document property name.
Case 3:20-cv-05787-SI Document 43-5 Filed 09/24/20 Page 18 of 18
1 [PROPOSED] ORDER
2 PURSUANT TO STIPULATION, IT IS SO ORDERED that:
3 1. Plaintiff’s Oppositions to any Rule 12 motions or other responses to the Complaint filed by
4 Defendants Facebook, Inc., Mark Zuckerberg, The Poynter Institute for Media Studies, Inc.,
5 and/or PolitiFact shall be due December 21, 2020.
6 2. Defendants’ Replies in support of any such Rule 12 motions shall be due January 21, 2021.
7 3.
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10 Dated: _______________________
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12 _____________________________
13 By: Hon. Susan Illston
United States District Judge
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CASE NO.: 3:20-CV-05787-SI [PROPOSED] ORDER ON CIVIL LOCAL RULE 6-2(A)
STIPULATION
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