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MATTHEW LAZARES, an individual, on behalf of himself, and all others similarly situated; Plaintiff, v. SHOPIFY (USA), INC., a Delaware corporation; and DOES 1 through 50, inclusive,

Action Filed: June 10, 2024

GIBSON, DUNN & CRUTCHER LLP

RACHEL S. BRASS, SBN 219301 rbrass@gibsondunn.com

JOSEPH R. ROSE, SBN 279092 jrose@gibsondunn.com

Attorneys for Defendant SHOPIFY (USA) INC.

GIBSON, DUNN & CRUTCHER LLP

RACHEL S. BRASS

JOSEPH R. ROSE

Attorneys for Defendant SHOPIFY (USA) INC.

Daniel Valles

Kayla Rathjen

Attorneys for Plaintiff

MATTHEW LAZARES, ON BEHALF OF

HIMSELF, AND ALL OTHERS SIMILARLY

SITUATED

JOINT STIPULATION AND ORDER EXTENDING OPPOSITION AND REPLY DEADLINES FOR DEFENDANT'S 12(C) MOTION

Pursuant to Civil Local Rules 6-1 and 6-2, Plaintiff Matthew Lazares (“Plaintiff') and Defendant Shopify (USA) Inc. (“Defendant”), acting by and through their respective counsel of record, hereby stipulate and respectfully submit as follows:

WHEREAS, on November 18, 2024, Defendant filed a Motion for Judgment on the Pleadings on Plaintiffs UCL Claim and All Requests for Equitable Relief pursuant to Federal Rule of Civil Procedure 12(c) (“12(c) Motion”), and noticed the hearing for January 23, 2025;

WHEREAS, pursuant to Civil Local Rules 7-3(a) and (c), the deadline for Plaintiff to file an opposition to Defendant's 12(c) Motion is December 2, 2024, and the deadline for Defendant to file a reply in support of the 12(c) Motion is December 9, 2024;

WHEREAS, having met and conferred, the Parties agree and respectfully submit that an extension of the aforementioned deadlines is warranted to minimize interference with the upcoming holidays and to accommodate one another's preexisting personal and professional obligations;

WHEREAS, the Parties have agreed and stipulate that Plaintiff shall have until December 23, 2024, to file any opposition, and that Defendant shall have until January 13, 2025, to file any reply;

WHEREAS, there have been no previous modifications of time in this case, and this extension of time will not alter the date of any event or deadline already fixed by Court Order;

NOW, THEREFORE, IT IS HEREBY STIPULATED, subject to this Court's approval, that:

1. Plaintiffs deadline to file an opposition to Defendant' s 12(c) Motion is extended to December 23, 2024; and
2. Defendant's deadline to file a reply in support of its 12(c) Motion is extended to January 13,2025.

IT IS SO STIPULATED.

CIVIL L.R. 5-l(i) ATTESTATION

Pursuant to Civil Local Rule 5-l(i), I, Rachel S. Brass, hereby attest under penalty of peijury that concurrence in the filing of this document has been obtained from all signatories.

ORDER

Having reviewed the Joint Stipulation and Proposed Order Extending Opposition and Reply Deadlines for Defendant's 12(c) Motion, PURSUANT TO STIPULATION, IT IS SO ORDERED that:

1. Plaintiffs deadline to file an opposition to Defendant's 12(c) Motion is extended to December 23, 2024; and

2. Defendant's deadline to file a reply in support of its 12(c) Motion is extended to January 13,2025.

IT IS SO ORDERED.

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Lazares v. Shopify (U.S.), Inc.
(Nov 21, 2024)