Invisible Narratives v. Next Level Apps Technology - FZCO

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JOINT STIPULATION REQUESTING AN EXTENSION OF THE ORDER REGARDING MOTION TO STRIKE
SCHEDULE
Jonathan Lagarenne (Pro Hac Vice)
Cali Spota (Pro Hac Vice)
Jonathan Madara (Pro Hac Vice)
FOX ROTHSCHILD LLP
212 Carnegie Center, Suite 400
Princeton, New Jersey 08540
Email: jlagarenne@foxrothschild.com
cspota@foxrothschild.com
jmadara@foxrothschild.com
Jack Praetzellis (SBN 267765)
FOX ROTHSCHILD LLP
345 California Street, Suite 2200
San Francisco, California 94104
Email:jpraetzellis@foxrothschild.com
John Joseph Shaeffer (SBN138331)
FOX ROTHSCHILD
10250 Constellation Blvd, Ste 900
Los Angeles, California 90067-6275
Email: jshaeffer@foxrothschild.com
Attorneys for Defendant
Next Level Apps Technology – FZCO
[Full Counsel listing on signature page]
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
INVISIBLE NARRATIVES LLC,
Plaintiff,
v.
NEXT LEVEL APPS TECHNOLOGY –
FZCO,
Defendant.
CASE NO. 5:25-cv-01644-NW
STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINES
PROVIDED IN COURT’S ORDER
REGARDING MOTION TO STRIKE
(ECF 118).
Case 5:25-cv-01644-NW Document 120 Filed 04/07/26 Page 1 of 3

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JOINT STIPULATION REQUESTING AN EXTENSION OF THE ORDER REGARDING MOTION TO STRIKE
SCHEDULE
Defendant Next Level Apps Technology–FZCO (“Defendant”) respectfully requests
leave for a modest extension of the deadlines established by the Court in its Order of April
1, 2026 Granting Motion to Strike and Order Denying Motion for Extension of Time
(“Order”) (ECF 118), and Plaintiff Invisible Narratives (“Plaintiff”) has agreed to stipulate
to that request. In support of this Request, the Parties stipulate as follows:
WHEREAS, pursuant to the Order, the Court granted Next Level leave to file an
opposition to Invisible Narrative’s Motion to Dismiss the first amended counterclaims
(“FACC”) by April 8, 2026;
WHEREAS, the Order provides that Plaintiff Invisible Narratives LLC (“Plaintiff”
or “Invisible Narratives”) may file a reply by April 15, 2026;
WHEREAS, pursuant to the Order, Invisible Narratives may file a motion seeking
sanctions or moving for attorney’s fees by April 15 2026;
WHEREAS, on April 3, 2026, Defendant sought Plaintiff’s consent for a short
extension of the April 8 deadline in light of certain scheduling constraints arising from, inter
alia, pre-planned vacations, the 2026 Passover and Easter holidays, and to accommodate
that request and avoid an extension that conflicts other deadlines and professional
obligations of all counsel. In view of that request, the Parties agreed to a short extension of
the deadlines established by the Court in the Order;
WHEREAS, under the Parties’ agreement, the deadline for Defendant’s response is
extended by three (3) business days and the deadline for Plaintiff’s anticipated motion is
extended by two (2) business days;
WHEREAS, the Parties agree that good cause exists for a short extension the
deadlines established by the Court;
WHEREAS, the Parties’ agreement is contingent upon and subject to Court approval,
and in the absence of the Court’s Order granting this request in full by April 8, all deadlines
shall remain as stated in ECF 118;
WHEREAS, the Parties agree that the requested extension will not cause any
unnecessary delay, unfairly prejudice any other party, or impact any current deadlines set
Case 5:25-cv-01644-NW Document 120 Filed 04/07/26 Page 2 of 3

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JOINT STIPULATION REQUESTING AN EXTENSION OF THE ORDER REGARDING MOTION TO STRIKE
SCHEDULE
by the Court;
WHEREAS, this is the Parties’ first request for an extension of time to comply with
the deadlines provided in the Order, other than the extension contained in the Order itself
of the January 6, 2026 deadline for Defendant to file its opposition to Plaintiff’s Motion to
Dismiss the First Amended Counterclaims;
NOW, THEREFORE, the Parties hereby stipulate and jointly request to extend the
deadlines in connection with the Order, and respectfully request that the Court issue an order
granting the following modification to the schedule:
Event 	Current Deadline 	Proposed Modified
Deadline
Next Level’s Opposition to
Plaintiff’s Motion to
Dismiss the First Amended
Counterclaims
Wednesday, April 8, 2026 	Monday, April 13, 2026
Invisible Narratives’
deadline to seek sanctions or
reasonable attorneys’ fees
Wednesday, April 15, 2026 	Friday, April 17, 2026
Invisible Narratives’ Reply
in support of its Motion to
Dismiss the First Amended
Counterclaims
Wednesday April 15, 2026 	Friday, April 23, 2026
Respectfully submitted,
DATED: April 6, 2026 	FOX ROTHSCHILD, LLP
By /s/Jonathan R. Lagarenne
Jonathan Lagarenne
Cali Spota
Jonathan Madara
Attorneys for Defendant
Next Level Apps Technology – FZCO
DATED: April 6, 2026 	COOLEY LLP
By /s/ Bobby A. Ghajar
Bobby A. Ghajar
Stephanie Schuyler
Attorneys for Plaintiff
Invisible Narratives LLC
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GRANTED
Judge Noël Wise
Case 5:25-cv-01644-NW Document 120 Filed 04/07/26 Page 3 of 3