Filed: Jan. 15, 2020
Latest Update: Jan. 15, 2020
Summary: JOINT STIPULATION AND ORDER FOR EXTENSION OF TIME TO RESPOND TO MOTION TO DISMISS JURY TRIAL DEMANDED WILLIAM H. ORRICK , District Judge . Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiff Stormborn Technologies, LLC and Defendant Topcon Positioning Systems, Inc. (collectively the "Parties"), by and through their counsel of record, hereby stipulate as follows: WHEREAS, Defendant filed its Motion to Dismiss ("Motion") on December 31, 2019 (Docket No. 16), and a hearing on the Motion is
Summary: JOINT STIPULATION AND ORDER FOR EXTENSION OF TIME TO RESPOND TO MOTION TO DISMISS JURY TRIAL DEMANDED WILLIAM H. ORRICK , District Judge . Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiff Stormborn Technologies, LLC and Defendant Topcon Positioning Systems, Inc. (collectively the "Parties"), by and through their counsel of record, hereby stipulate as follows: WHEREAS, Defendant filed its Motion to Dismiss ("Motion") on December 31, 2019 (Docket No. 16), and a hearing on the Motion is ..
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JOINT STIPULATION AND ORDER FOR EXTENSION OF TIME TO RESPOND TO MOTION TO DISMISS
JURY TRIAL DEMANDED
WILLIAM H. ORRICK, District Judge.
Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiff Stormborn Technologies, LLC and Defendant Topcon Positioning Systems, Inc. (collectively the "Parties"), by and through their counsel of record, hereby stipulate as follows:
WHEREAS, Defendant filed its Motion to Dismiss ("Motion") on December 31, 2019 (Docket No. 16), and a hearing on the Motion is set for February 5, 2020;
WHEREAS, Plaintiff's response to the Motion was originally due by January 14, 2020, and Defendant's reply was due by January 21, 2020;
WHEREAS, Plaintiff requests additional time to respond to the Motion to allow counsel sufficient time to address the Motion that seeks to invalidate all claims in the asserted patent;
WHEREAS, no party will be prejudiced by this extension;
WHEREAS, this is Plaintiff's first request for an extension of time in connection with this Motion;
NOW, THEREFORE, the Parties, by and through the undersigned counsel, hereby request that the Court extend Plaintiff's time to respond to the Motion to Dismiss from January 14, 2020 to January 21, 2020, and Defendant's time to reply from January 21, 2020 to February 4, 2020.
FURTHER, the Parties request that the hearing currently scheduled for February 5, 2020 at 2:00 p.m. be continued to March 4, 2020 at 2:00 p.m.
IT IS SO STIPULATED.
Dated: January 14, 2020 Respectfully submitted,
OF COUNSEL: /s/Kirk J. Anderson
KIRK. J. ANDERSON (SBN 289043)
kanderson@budolaw.com
Howard L. Wernow
(pro hac vice forthcoming) BUDO LAW, P.C.
SAND, SEBOLT & WERNOW 5610 Ward Rd., Suite #300
CO., LPA Arvada, CO 80002
Aegis Tower — Suite 1100 (720) 225-9440 (Phone)
4940 Munson Street, N. W. (720) 225-9331 (Fax)
Canton, Ohio 44718
Phone: 330-244-1174 ATTORNEYS FOR PLAINTIFF
Fax: 330-244-1173
howard.wernow@sswip.com
Neil J. McNabnay, pending pro hac vice /s/Rodeen Talebi
Texas Bar No. 24002583 RODEEN TALEBI (SBN 320392)
mcnabnay@fr.com FISH & RICHARDSON P.C.
Ricardo J. Bonilla, pending pro hac vice 500 Arguello Street, Suite 500
Texas Bar No. 24082704 Redwood City, CA 94063
rbonilla@fr.com (650) 839-5070 (Phone)
Michael A. Vincent, pending pro hac vice (650) 839-5071 (Fax)
Texas Bar No. 24105738
vincent@fr.com
FISH & RICHARDSON, P.C. ATTORNEYS FOR DEFENDANT
1717 Main Street, Suite 5000
Dallas, Texas 75201
Telephone: (214) 747-5070
Facsimile: (214) 747-2091
ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
