Huiskamp v. ZoomInfo Technologies LLC

1 HON. DAVID G. ESTUDILLO

8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 9 AT TACOMA KELLY HUISKAMP, individually and on Case No. 3:25-cv-05443-DGE behalf of all others similar situated, 13 Plaintiff, STIPULATED MOTION TO EXTEND TIME TO RESPOND TO 14 v. AMENDED COMPLAINT, SET BRIEFING SCHEDULE, AND ZOOMINFO TECHNOLOGIES LLC, a INCREASE PAGE LIMITS Delaware corporation, Defendant.

1 Plaintiff Kelly Huiskamp and defendant ZoomInfo Technologies LLC hereby jointly move the Court for an order extending the deadline for defendant to respond to plaintiff’s amended complaint, to enter a briefing schedule on defendant’s intended motion to dismiss the amended complaint, and to increase the word limit for ZoomInfo to respond to anticipated opposition and amicus briefs.

6 On April 16, 2025, plaintiff filed the summons and complaint against defendant in the Superior Court for the State of Washington in and for the County of Clark (“State Court”).

9 On May 8, 2025, plaintiff and defendant filed a stipulation in the State Court extending defendant’s time to respond to the complaint to June 6, 2025, and a proposed order to that effect.

12 On May 9, 2025, the State Court entered an order approving the stipulation and extending defendant’s time to respond to the complaint to June 6, 2025.

14 On May 16, 2025, defendant filed a Notice of Removal to the U.S. District Court for the Western District of Washington.

16 The parties then filed a stipulated motion extending defendant’s time to respond to the complaint until June 30, 2025.

18 On June 30, 2025, defendant moved to dismiss the complaint.

19 On July 3, 2025, the parties stipulated to extend plaintiff’s time to oppose defendant’s motion to dismiss to August 18, 2025, and for defendant to file its reply to September 8, 2025.

22 On August 18, 2025, plaintiff filed an amended complaint. Absent further agreement of the parties and Order of the Court, defendant’s response to the amended complaint is due September 2, 2025.

25 The parties are scheduled to confer with representatives of the Office of the Attorney General of the State of Colorado on August 27, 2025, to discuss the Attorney General’s intention to seek leave to file an amicus brief on behalf of Colorado and together with the Attorneys General of other states.

3 Now, the parties jointly ask the Court to extend defendant’s deadline to respond to the amended complaint to September 22, 2025, and, if defendant moves to dismiss the amended complaint, that plaintiff’s date to oppose be extended to October 20, 2025, and the date for defendant’s reply to November 17, 2025.

7 Further, the parties have conferred with the Attorney General of Colorado and consent to granting leave to the Attorney General of Colorado to file an amicus brief.

9 The parties and the Attorney General of Colorado have further agreed that the deadline for the Attorney(s) General to file an amicus brief in this matter will be seven (7) days after plaintiff files its opposition to defendant’s motion to dismiss the amended complaint.

13 For the avoidance of doubt, the parties further agree that if defendant moves to dismiss the amended complaint, defendant will have no obligation to file an answer to the amended complaint, pending the Court’s ruling on the motion to dismiss.

16 In light of the parties’ agreement, plaintiff’s addition of further factual allegations in the amended complaint, and the expected request for the Attorneys General of Colorado and other states to seek leave to file an amicus brief in the case, there is good cause for the requested extensions, and they will not prejudice any party.

20 The parties further agree that for these same reasons—including that ZoomInfo will be responding to the amicus brief as well as plaintiff’s opposition brief—the word limit for ZoomInfo’s reply in support of its motion to dismiss be increased from 4,200 words to 6,500 words.

24 WHEREFORE, the parties respectfully request an Order modifying the current case deadlines and page limits as described herein.

26 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

1 DATED: August 29, 2025 QUINN EMANUEL URQUHART & SULLIVAN, LLP By /s/ Matthew Hosen Matthew Hosen, WSBA #54855 5 [email protected] 1109 First Avenue, Suite 210 Seattle, Washington 98101 7 (206) 905-7000 Attorneys for Defendant 9 ZoomInfo Technologies LLC DATED: August 29, 2025 EMERY REDDY PLLC 13 By /s/ Timothy W. Emery 14 Timothy W. Emery, WSBA No. 34078 [email protected] Patrick B. Reddy, WSBA No. 34092 16 [email protected] Paul Cipriani, WSBA no. 59991 [email protected] 18 600 Stewart St., Suite 1100 Seattle, Washington 98101 (206) 442-9106 Attorneys for Plaintiff Kelly Huiskamp

1 Having reviewed the Parties’ stipulation, the stipulated motion to extend time and set briefing schedule (Dkt. No. 22) is GRANTED.

3 Defendant shall respond to the Amended Complaint by September 22, 2025. If a motion to dismiss is filed, Plaintiff shall file a response to said motion by October 20, 2025. Any amicus brief by the Attorney General of Colorado shall be filed by October 27, 2025. Defendant’s reply to the opposition and to any amicus brief shall be filed by November 17, 2025 and the word limit for such reply shall be 6,500 words.

8 The Court also DENIES as moot Defendant’s motion to dismiss (Dkt. No. 16) Plaintiff’s original complaint (Dkt. No. 1-1.) On July 7, 2025, the Court granted (Dkt.

10 No. 19) Plaintiff motion to amend his complaint (Dkt. No. 18). Plaintiff timely filed his amended complaint on August 18, 2025. (Dkt. No. 21.) Plaintiff’s amended complaint supersedes his original complaint. See Valadez v. Chertoff, 656 F.3d 851, 857 (9th Cir. 2011); Umouyo v. Bank of America NA, 2022 WL 2392386, at *1 (W.D. Wash. July 1, 2022).

16 DATED this 5th day of September, 2025 A David G. Estudillo United States District Judge