Liebick et al v. Samsung Electronics America, Inc. et al

STIPULATION & ORDER TO EXTEND PLAINTIFFS’ DEADLINE TO FILE 3 RD AMENDED COMPLAINT
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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

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STIPULATION & ORDER TO EXTEND PLAINTIFFS’ DEADLINE TO FILE 3 RD AMENDED COMPLAINT
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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.

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STIPULATION & ORDER TO EXTEND PLAINTIFFS’ DEADLINE TO FILE 3 RD AMENDED COMPLAINT
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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.

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STIPULATION & ORDER TO EXTEND PLAINTIFFS’ DEADLINE TO FILE 3 RD AMENDED COMPLAINT
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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