THIRD STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT [N.D. CAL. L.R. 6-1(b) and 6-2];
DECLARATION OF ANDREW P. VALENTINE;
[PROPOSED] ORDER
JON S. TIGAR, District Judge.
JOINT STIPULATION
Plaintiff HDMI Licensing Administrator, Inc. ("Plaintiff") and Defendant Chunghsin Technology Group Co., Ltd. f/k/a New Century Optronics Co., Ltd. ("Defendant") enter into the following stipulation, pursuant to Local Rules 6-1(b) and 6-2, extending Defendant's time to respond to Plaintiff's Complaint (the "Complaint") and requesting a short extension to case management deadlines:
WHEREAS, Plaintiff's Complaint was filed on January 4, 2019;
WHEREAS, Plaintiff contends Defendant was personally served with the Complaint on January 8, 2019;
WHEREAS, the parties stipulated to an extension of Defendant's time to respond to the Complaint from January 29, 2019 to February 19, 2019 (Docket Entry No. 9);
WHEREAS, the parties stipulated to an second extension of Defendant's time to respond to the Complaint from February 19, 2019 to March 5, 2019 (Docket Entry No. 10);
WHEREAS, since the filing of the second stipulation, the parties have continued to engage in discussions regarding settlement;
WHEREAS, as part of those discussions, Defendant has agreed not to contest service of process of the Summons and Complaint;
WHEREAS, the parties have continued to engage in discussions regarding settlement and have agreed to a third extension of time in accordance with Local Rule 6-1(a) until April 1, 2019 for Defendant to respond to Plaintiff's Complaint;
WHEREAS, because the stipulated response date falls between currently existing case management dates, the parties respectfully request that the case management deadlines be continued as follows, pursuant to Local Rule 6-2:
Event From (current) To
LD conduct case management March 27, 2019 April 24, 2019
meet and confer per FRCP 26
LD parties submit Joint CMC April 10, 2019 May 8, 2019
Statement
Initial Case Management April 17, 2019 May 15, 2019
Conference 2:00 p.m. 2:00 pm
WHEREAS, the stipulated extension will permit the parties to continue to confer about their claims and defenses in this action and a potential resolution.
NOW, THEREFORE, IN CONSIDERATION OF THE FOREGOING:
1. IT IS HEREBY STIPULATED by and between the parties that, pursuant to Local Rule 6-1(a), Defendant shall have up to and including April 1, 2019 to respond to Plaintiff's Complaint.
2. IT IS FURTHER STIPULATED AND THE PARTIES JOINTLY REQUEST that the current case management deadlines be continued as follows, pursuant to Local Rule 6-2:
Event From (current) To
LD conduct case management March 27, 2019 April 24, 2019
meet and confer per FRCP 26
LD parties submit Joint CMC April 10, 2019 May 8, 2019
Statement
Initial Case Management April 17, 2019 May 15, 2019
Conference 2:00 p.m. 2:00 pm
DECLARATION OF ANDREW P. VALENTINE
I, Andrew P. Valentine, declare as follows:
1. I am a partner at DLA Piper LLP (US) and represent Defendant Chunghsin Technology Group Co., Ltd. f/k/a New Century Optronics Co., Ltd. in this matter.
2. The parties initially stipulated to an extension of Defendant's time to respond to the Complaint from January 29, 2019 to February 19, 2019 (Docket Entry No. 9).
3. The parties subsequently agreed to a second extension extending Defendant's time to respond to the Complaint from February 19, 2019 to March 5, 2019 (Docket Entry No. 10).
4. Since the filing of the second stipulation, the parties have continued to engage in discussions regarding settlement.
5. As part of those discussions, Defendant has agreed not to contest service of process of the Summons and Complaint.
6. To allow the parties to continue to engage in discussions regarding settlement, the parties have agreed to a third extension of time, until April 1, 2019, for Defendant to respond to Plaintiff's Complaint. The parties have also stipulated to the revise case management dates contained herein.
7. The purpose of the parties' stipulations are to allow the parties to continue to engage in discussions regarding settlement.
I declare under the penalty of perjury, under the laws of the United States of America that the foregoing is true and correct and that this declaration was executed on this 5th day of March, 2019, at East Palo Alto, California.
ANDREW P. VALENTINE
ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
ATTESTATION
I, Andrew P. Valentine, am the ECF User whose identification and password are being used to file the THIRD STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT [N.D. CAL. L.R. 6-1(a) AND 6-2]. In compliance with Civil Local Rule 5-1(i)(3), I hereby attest that Jason Drangel, counsel for Plaintiff HDMI Licensing Administrator, Inc., has concurred in this filing.
