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Case 8:21-cv-02359-PJM Document 16 Filed 12/23/21 Page 1 of 3
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MARYLAND
`
`HADONA DIEP,
`
` Plaintiff,
`
`v.
`
`APPLE, INC.,
`
` Defendant.
`
`Civil Action No.: 8:21-cv-02359-PJM
`
`STIPULATION REGARDING MOTION TO TRANSFER VENUE
`AND DEADLINE TO RESPOND TO COMPLAINT
`
`IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff Hadona Diep
`
`(“Plaintiff”) and Defendant Apple Inc. (“Defendant”), through their undersigned counsel, subject
`
`to the approval of the Court, as follows:
`
`1.
`
`Plaintiff filed her Complaint in the above-referenced matter on September 16,
`
`2021 (ECF No. 1).
`
`2.
`
`On November 4, 2021, Plaintiff moved to transfer the case to the United States
`
`District Court for the Northern District of California (ECF No. 13).
`
`3.
`
`Defendant was served with the Complaint on December 9, 2021, and a Proof of
`
`Service was filed with the Court on December 16, 2021 (ECF No. 14).
`
`4.
`
`The parties met and conferred on December 16, 2021, and Defendant consents to
`
`Plaintiff’s motion to transfer venue (ECF No. 13).
`
`5.
`
`The parties further stipulate and agree that Defendant’s response to the Complaint
`
`shall be due forty-five (45) days after the date on which this case is transferred and opened by the
`
`Court in the United States District Court for the Northern District of California.
`
`EAST\186949489.1
`
`

`

`Case 8:21-cv-02359-PJM Document 16 Filed 12/23/21 Page 2 of 3
`
`Dated: December 23, 2021
`
`PLAINTIFF
`
`
`
`HADONA DIEP,
`
`
`
`/s/ Edward N. Griffin____________
`Edward N. Griffin (Bar No. 16435)
`
`Joshua G. Whitaker (Bar No. 16457)
`
`ADELPHI LAW
`2306 Wineberry Terrace
`Baltimore, MD 21209
`T: (888) 367-0383
`
`F: (888) 367-0383
`
`griffin@adelphilaw.com
`whitaker@adelphilaw.com
`
`DEFENDANT
`
`APPLE INC.
`
`/s/ A. Neill Thupari____________________
`Michael P. O’Day (Bar No. 27075)
`Ellen E. Dew (Bar No. 28830)
`A. Neill Thupari (Bar No. 13065)
`Emily M. Steiner (Bar No. 20433)
`
`DLA PIPER LLP (US)
`The Marbury Building
`6225 Smith Avenue
`Baltimore, MD 21209
`T: (410) 580-3000
`F: (410) 580-3001
`michael.oday@us.dlapiper.com
`ellen.dew@us.dlapiper.com
`neill.thupari@us.dlapiper.com
`emily.m.steiner@us.dlapiper.com
`
`EAST\186949489.1
`
`

`

`Case 8:21-cv-02359-PJM Document 16 Filed 12/23/21 Page 3 of 3
`
`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that on this 23rd day of December 2021, a copy of the foregoing
`
`was filed with the Clerk of the Court using the CM/ECF system, which will serve all counsel of
`
`record.
`
`/s/ A. Neill Thupari____________________
`A. Neill Thupari (Bar No. 13065)
`Counsel for Defendant Apple Inc.
`
`EAST\186949489.1
`
`

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