Aarons et al v. NextRoll, Inc.

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JOINT STIPULATION TO MODIFY BRIEFING SCHEDULE ON MOTION TO DISMISS -
3:26-cv-08661-CRB
LEGAL\118745781\1
Matthew W. Ruan (SBN 264409)
mruan@jjlmlaw.com
Nicholas R. Lange (pro hac vice)
nlange@jjlmlaw.com
JUSTICE JAGHER LONDON & MILLEN LLC
100 Tri-State International, Suite 128
Lincolnshire, IL 60069
Telephone: (224) 632-4500
Attorneys for Plaintiffs and the Putative Class
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
AIDAN AARONS and SEAN
POLLARD, individually and on behalf of
all others similarly situated,
Plaintiffs,
vs.
NEXTROLL, INC., a Delaware
corporation,
Defendant.
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Case No. 3:26-cv-08661-CRB
[Assigned to Hon. Charles R. Breyer]
JOINT STIPULATION TO
MODIFY BRIEFING SCHEDULE
ON DEFENDANT’S MOTION TO
DISMISS
[Civil L.R. 6-1(b), 6-2, 7-12]
Current Opposition Date: Oct. 14, 2026
New Opposition Date: Oct. 28, 2026
Current Reply Date: Oct. 21, 2026
New Reply Date: Nov. 11, 2026
Hearing Date: November 20, 2026
Time: 10:00 a.m.
Courtroom: 6, 17th Floor
By and through their respective undersigned counsel, pursuant to Civil Local
Rules 6-1(b), 6-2, and 7-12, and Paragraph I.B.7 of the Court’s General Standing
Order for Civil and Criminal Cases, Plaintiffs Aidan Aarons and Sean Pollard,
individually and on behalf of all others similarly situated (“Plaintiffs”), and Defendant
NextRoll, Inc. (“Defendant,” collectively with Plaintiffs, the “Parties”), hereby
stipulate and jointly request an order modifying the briefing schedule on Defendant’s
: MODIFIED ORDER
Case 3:26-cv-08661-CRB Document 18 Filed 10/08/26 Page 1 of 9

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JOINT STIPULATION TO MODIFY BRIEFING SCHEDULE ON MOTION TO DISMISS -
3:26-cv-08661-CRB
LEGAL\118745781\1
Motion to Dismiss as follows:
WHEREAS, on June 10, 2026, Plaintiffs initiated this action against Defendant
in the Superior Court of California for the County of San Francisco, captioned Aidan
Aarons, et al. v. NextRoll, Inc., Case Number CGC-26-637769, and on August 19,
2026, Defendant removed the action to this Court (ECF No. 1);
WHEREAS, on August 26, 2026, the Parties filed a stipulation pursuant to
Civil Local Rule 6-1(a) extending Defendant’s time to respond to the Complaint from
August 26, 2026 to September 30, 2026 (ECF No. 7);
WHEREAS, on September 9, 2026, this action was reassigned to the Honorable
Charles R. Breyer (ECF No. 12);
WHEREAS, on September 30, 2026, Defendant filed its Motion to Dismiss
Plaintiffs’ Complaint (ECF No. 15) and an accompanying Request for Judicial Notice
(ECF No. 16) (collectively, the “Motion”), and noticed the Motion for hearing on
November 20, 2026 at 10:00 a.m.;
WHEREAS, pursuant to Civil Local Rule 7-3, Plaintiffs’ opposition to the
Motion is currently due on October 14, 2026, and Defendant’s reply is currently due
on October 21, 2026;
WHEREAS, the Motion seeks dismissal of each of Plaintiffs’ eight causes of
action on multiple independent grounds and is supported by a 43-page Request for
Judicial Notice, including four exhibits of legislative history;
WHEREAS, Given the breadth of issues raised and length of associated
briefing, Plaintiffs’ counsel requires additional time beyond the fourteen days
provided by Civil Local Rule 7-3(a) to adequately research and brief the numerous
arguments Defendant raises in support of dismissal;
WHEREAS, For the same reasons, Defendants require an extension of time
beyond the seven days provided by Civil Local Rule 7-3(c) to prepare and file their
reply in support of the Motion;
Case 3:26-cv-08661-CRB Document 18 Filed 10/08/26 Page 2 of 9

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JOINT STIPULATION TO MODIFY BRIEFING SCHEDULE ON MOTION TO DISMISS -
3:26-cv-08661-CRB
LEGAL\118745781\1
WHEREAS, Plaintiffs therefore requested, and Defendant agreed to, a two-
week extension of Plaintiffs’ deadline to oppose the Motion, together with a three-
week extension of Defendant’s deadline to reply, as set forth more fully in the
accompanying Declaration of Matthew W. Ruan;
WHEREAS, this is the Parties’ first request to modify the briefing schedule on
the Motion, and the only prior time modification in this action is the stipulated
extension of Defendant’s time to respond to the Complaint (ECF No. 7);
WHEREAS, the requested modification will not alter the November 20, 2026
hearing date on the Motion, and this Stipulation is being filed more than fourteen days
before the hearing in accordance with Civil Local Rule 6-1(b);
NOW, THEREFORE, the Parties stipulate and agree, subject to the Court’s
approval, that: (1) Plaintiffs’ deadline to file and serve their opposition to the Motion
is extended from October 14, 2026 to October 28, 2026; (2) Defendant’s deadline to
file and serve its reply in support of the Motion is extended from October 21, 2026 to
November 12, 2026; and (3) the hearing on the Motion shall remain on calendar for
November 20, 2026 at 10:00 a.m. in Courtroom 6, 17th Floor, before the Honorable
Charles R. Breyer.
IT IS SO STIPULATED.
Dated: October 7, 2026 	JUSTICE JAGHER LONDON & MILLEN LLC
By: /s/ Matthew W. Ruan
Matthew W. Ruan
Nicholas R. Lange (pro hac vice)
Attorneys for Plaintiffs and the Putative
Class
Case 3:26-cv-08661-CRB Document 18 Filed 10/08/26 Page 3 of 9

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JOINT STIPULATION TO MODIFY BRIEFING SCHEDULE ON MOTION TO DISMISS -
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LEGAL\118745781\1
Dated: October 7, 2026 	COZEN O’CONNOR
By: /s/ Matthew E. Lewitz
Matthew E. Lewitz
Madeline J. Suchard
Attorneys for Defendant NextRoll, Inc.
ATTESTATION PER N.D. CAL. CIVIL L.R. 5-1(i)(3)
I, Matthew W. Ruan, attest that all other signatories listed, and on whose
behalf the filing is submitted, concur in the filing’s content and have authorized the
filing.
Dated: October 7, 2026 	/s/ Matthew W. Ruan
Matthew W. Ruan
Case 3:26-cv-08661-CRB Document 18 Filed 10/08/26 Page 4 of 9

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RUAN DECLARATION ISO JOINT STIPULATION TO MODIFY BRIEFING SCHEDULE -
3:26-cv-08661-CRB
LEGAL\118745876\1
Matthew W. Ruan (SBN 264409)
mruan@jjlmlaw.com
Nicholas R. Lange (pro hac vice)
nlange@jjlmlaw.com
JUSTICE JAGHER LONDON & MILLEN LLC
100 Tri-State International, Suite 128
Lincolnshire, IL 60069
Telephone: (224) 632-4500
Attorneys for Plaintiffs and the Putative Class
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
AIDAN AARONS and SEAN
POLLARD, individually and on behalf of
all others similarly situated,
Plaintiffs,
vs.
NEXTROLL, INC., a Delaware
corporation,
Defendant.
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Case No. 3:26-cv-08661-CRB
[Assigned to Hon. Charles R. Breyer]
DECLARATION OF MATTHEW
W. RUAN IN SUPPORT OF JOINT
STIPULATION TO MODIFY
BRIEFING SCHEDULE ON
DEFENDANT’S MOTION TO
DISMISS
[Civil L.R. 6-2(a)]
Hearing Date: November 20, 2026
Time: 10:00 a.m.
Courtroom: 6, 17th Floor
I, Matthew W. Ruan, declare as follows:
1. 	I am an attorney licensed to practice law in the State of California and
admitted to practice before this Court, and I am a partner of Justice Jagher London &
Millen LLC, counsel of record for Plaintiffs Aidan Aarons and Sean Pollard
(“Plaintiffs”) in this action. I submit this declaration pursuant to Civil Local Rule 6-
2(a) in support of the Parties’ Joint Stipulation to Modify Briefing Schedule on
Defendant’s Motion to Dismiss. I have personal knowledge of the facts set forth
herein and, if called as a witness, could and would testify competently thereto.
Case 3:26-cv-08661-CRB Document 18 Filed 10/08/26 Page 5 of 9

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RUAN DECLARATION ISO JOINT STIPULATION TO MODIFY BRIEFING SCHEDULE -
3:26-cv-08661-CRB
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2. 	On September 30, 2026, Defendant NextRoll, Inc. (“Defendant”) filed
its Motion to Dismiss Plaintiffs’ Complaint (ECF No. 15) and an accompanying
Request for Judicial Notice (ECF No. 16) (collectively, the “Motion”), noticed for
hearing on November 20, 2026 at 10:00 a.m. Pursuant to Civil Local Rule 7-3,
Plaintiffs’ opposition to the Motion is currently due on October 14, 2026, and
Defendant’s reply is currently due on October 21, 2026.
3. 	The Motion seeks dismissal of Plaintiffs’ Complaint in its entirety and
challenges each of Plaintiffs’ eight causes of action on multiple independent grounds,
including Plaintiffs’ claims under California Penal Code sections 631, 632, and
638.51, the California Comprehensive Computer Data Access and Fraud Act, the
federal Wiretap Act, common law intrusion upon seclusion and the California
constitutional right to privacy, and the Unfair Competition Law. The Motion is
accompanied by a 43-page Request for Judicial Notice, which includes four exhibits
of legislative history, that Plaintiffs must also review and address.
4. 	Given the breadth of the issues raised and the length of the associated
briefing, the fourteen days provided by Civil Local Rule 7-3(a) are insufficient for
Plaintiffs’ counsel to research each argument Defendant raises in support of dismissal
and prepare a comprehensive opposition. For the same reasons, Defendants require
an extension of time beyond the seven days provided by Civil Local Rule 7-3(c) to
prepare and file their reply in support of the Motion. Plaintiffs therefore requested a
two-week extension of their opposition deadline, to October 28, 2026, and Defendant
agreed to that request. The Parties further agreed to extend Defendant’s reply deadline
three weeks, to November 12, 2026.
4. 	There has been one prior time modification in this action: on August 26,
2026, the Parties stipulated, pursuant to Civil Local Rule 6-1(a) and without a Court
order, to extend Defendant’s time to respond to the Complaint from August 26, 2026
Case 3:26-cv-08661-CRB Document 18 Filed 10/08/26 Page 6 of 9

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RUAN DECLARATION ISO JOINT STIPULATION TO MODIFY BRIEFING SCHEDULE -
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LEGAL\118745876\1
to September 30, 2026 (ECF No. 7).1 No other time modifications have been
requested or ordered in this action, and this is the Parties’ first request to modify the
briefing schedule on the Motion.
5. 	The requested modification will not alter the November 20, 2026 hearing
date on the Motion. No trial date or other case-wide deadlines have been set.
6. 	Counsel for Defendant has reviewed the Stipulation and has authorized
me to file it on Defendant’s behalf with Defendant’s counsel’s electronic signature.
I declare under penalty of perjury under the laws of the United States of
America that the foregoing is true and correct.
Executed on October 7, 2026, at Lincolnshire, Illinois.
/s/ Matthew W. Ruan
Matthew W. Ruan
1 In addition, following the reassignment of this action to the Honorable Charles
R. Breyer on September 9, 2026 (ECF No. 12), the Clerk reset the Initial Case
Management Conference from November 17, 2026 to November 20, 2026 at 8:30
a.m., with the Joint Case Management Statement due November 13, 2026 (ECF No.
13).
Case 3:26-cv-08661-CRB Document 18 Filed 10/08/26 Page 7 of 9

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[PROPOSED] ORDER MODIFYING BRIEFING SCHEDULE ON MOTION TO DISMISS -
3:26-cv-08661-CRB
LEGAL\118745907\1
Matthew W. Ruan (SBN 264409)
mruan@jjlmlaw.com
Nicholas R. Lange (pro hac vice)
nlange@jjlmlaw.com
JUSTICE JAGHER LONDON & MILLEN LLC
100 Tri-State International, Suite 128
Lincolnshire, IL 60069
Telephone: (224) 632-4500
Attorneys for Plaintiffs and the Putative Class
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
AIDAN AARONS and SEAN
POLLARD, individually and on behalf of
all others similarly situated,
Plaintiffs,
vs.
NEXTROLL, INC., a Delaware
corporation,
Defendant.
)
)
)
)
)
)
)
)
)
)
)
)
)
)
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Case No. 3:26-cv-08661-CRB
[Assigned to Hon. Charles R. Breyer]
[PROPOSED] ORDER GRANTING
JOINT STIPULATION TO
MODIFY BRIEFING SCHEDULE
ON DEFENDANT’S MOTION TO
DISMISS
Hearing Date: November 20, 2026
Time: 10:00 a.m.
Courtroom: 6, 17th Floor
Having considered the Parties’ Stipulation to Modify Briefing Schedule on
Defendant’s Motion to Dismiss and the accompanying Declaration of Matthew W.
Ruan, and good cause appearing, the Court ORDERS as follows:
1. 	Plaintiffs’ deadline to file and serve their opposition to Defendant’s
Motion to Dismiss (ECF No. 15) is extended to October 28, 2026;
2. 	Defendant’s deadline to file and serve its reply in support of the Motion
to Dismiss is extended to November 12, 2026; and
3. 	The hearing on the Motion to Dismiss remains on calendar for Novemberset for December 4, 2026 at 10:00 a.m. by video conference.
Case 3:26-cv-08661-CRB Document 18 Filed 10/08/26 Page 8 of 9

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[PROPOSED] ORDER MODIFYING BRIEFING SCHEDULE ON MOTION TO DISMISS -
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20, 2026 at 10:00 a.m. in Courtroom 6, 17th Floor.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated: ____________________
HON. CHARLES R. BREYER
United States District Judge
video conference (Zoom)
October 8, 2026
Case 3:26-cv-08661-CRB Document 18 Filed 10/08/26 Page 9 of 9