2:25-cv-01300•Liebick et al v. Samsung Electronics America, Inc. et al
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STIPULATION & ORDER TO EXTEND PLAINTIFFS’ DEADLINE TO FILE 3 RD AMENDED COMPLAINT 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 RONALD J. COOK- SBN 121398 COOK LAW GROUP 20 S. Santa Cruz Avenue, Street, Suite 310 Los Gatos, California 95030 Telephone: (408) 494-9211 Facsimile: (408) 493-0400 ron@roncooklawgroup.com Attorneys for Plaintiffs NEIL LIEBICK, SHARON CLARK, individually and as guardian ad litem for JANE DOE 1, JANE DOE 2, and JOHN DOE; and JASON FRANKLIN UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA NEIL LIEBICK, SHARON CLARK, individually and as guardian ad litem for JANE DOE 1, JANE DOE 2, and JOHN DOE; and JASON FRANKLIN, Plaintiffs, v. SAMSUNG ELECTRONICS AMERICA, INC., COSTCO WHOLESALE CORP., and DOES 1-10, Defendants. Case No. 2:25-cv-01300-DJC-DMC STIPULATION AND ORDER TO EXTEND PLAINTIFFS’ DEADLINE TO FILE THIRD AMENDED COMPLAINT Removal Filed: May 5, 2025
2 STIPULATION & ORDER TO EXTEND PLAINTIFFS’ DEADLINE TO FILE 3 RD AMENDED COMPLAINT 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiffs NEIL LIEBICK, SHARON CLARK, individually and as guardian ad litem for JANE DOE 1, JANE DOE 2, and JOHN DOE; and JASON FRANKLIN (“Plaintiffs”) and Defendants SAMSUNG ELECTRONICS AMERICA, INC. and COSTCO WHOLESALE CORP. also (“Defendants” (collectively “Parties”), through their respective counsel, hereby stipulate and agree as follows: WHEREAS, on November 6, 2025, the Court granted in part and denied in part Defendants’ Motion to Dismiss the Second Amended Complaint; (ECF No. 29); WHEREAS, the Court’s Minute Order provides Plaintiffs twenty (20) days to file a Third Amended Complaint, setting a deadline of November 26, 2025 (ECF 29); WHEREAS, on November 10, 2025, Defendant SAMSUNG ELECTRONICS AMERICA, INC. requested a copy of the court reporter’s transcript of the November 6, 2025, hearing, with said transcript scheduled to arrive within 14 days (ECF 30); WHEREAS, as of November 25, 2025, a transcript has not yet been received by the Parties; WHEREAS, absent a written order from the Court, and without a copy of the transcript, Plaintiffs are unsure exactly how the Court ruled on the motion and are therefore not clear on how to amend the Complaint in a way that will not invite a new Motion to Dismiss; WHEREAS, this stipulation is made in good faith and not for the purpose of delay. NOW THEREFORE, in consideration of the foregoing, the Parties, by and through their respective counsel of record, HEREBY STIPULATE and respectfully request that the Court enter an order extending Plaintiffs’ deadline to file their Third Amended Complaint until five (5) court days after the parties receive a copy of the court reporter’s transcript of the November 6, 2025, hearing; The Parties FURTHER STIPULATE that in recognition of the Holiday schedule for counsel, Defendants’ responsive pleading to the Third Amended Complaint shall be extended from December 17, 2025, to January 6, 2026. IT IS SO STIPULATED.
3 STIPULATION & ORDER TO EXTEND PLAINTIFFS’ DEADLINE TO FILE 3 RD AMENDED COMPLAINT 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: November 26, 2025 COOK LAW GROUP By: /s/ Ronald J. Cook Ronald J. Cook Attorney for Plaintiffs Dated: November 26, 2025 GREENBERG TRAURIG, LLP By: /S/ Robert J. Herrington Anna Yeung Attorneys for Defendant SAMSUNG ELECTRONICS AMERICA, INC. Dated: November 26, 2025 MAIRE & DEEDON By: /S/ Patrick Deedon Attorney for Defendant COSTCO WHOLESALE CORP.
4 STIPULATION & ORDER TO EXTEND PLAINTIFFS’ DEADLINE TO FILE 3 RD AMENDED COMPLAINT 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ORDER Pursuant to the Parties’ Stipulation to Extend Plaintiffs’ Deadline to File their Third Amended Complaint and to Extend the deadline for Defendants to file a Responsive Pleading, and good cause appearing, the Court orders Plaintiffs’ Deadline to File their Third Amended Complaint is extended until five court (5) days after the Parties receive a copy of the court reporter’s transcript of the November 6, 2025 hearing with Defendants’ deadline to file a responsive pleading extended to January 6, 2026. IT IS SO ORDERED. Dated: November 26, 2025 /s/ Daniel J. Calabretta THE HONORABLE DANIEL J. CALABRETTA UNITED STATES DISTRICT JUDGE
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