JOINT STIPULATION TO EXTEND TIME TO REPLY REGARDING MOTION TO LIFT STAY AND CONTINUE HEARING DATE FOR MOTION AND CASE MANAGEMENT CONFERENCE

EDWARD M. CHEN, Magistrate Judge.

Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiff Robert Bosch Healthcare Systems, Inc. ("Bosch") and Defendant Cardiocom, LLC ("Cardiocom") hereby submit this Joint Stipulation to Extend Time to Reply Regarding Motion to Lift Stay and Continue Hearing Date for Motion and Case Management Conference. The parties stipulate that Bosch's reply brief regarding its Motion to Lift Stay (Dkt. 171) may be extended from January 26, 2017 to February 2, 2017. Bosch requests the extension so it can work with Bosch's representatives in Germany to respond to Cardiocom's opposition.

The hearings for Bosch's Motion to Lift Stay and the Case Management Conference are currently scheduled for February 23, 2017 at 1:30. (Dkts. 171 and 173.) The parties stipulate and request that the Court continue the Case Management Conference to March 2, 2017 in order to accommodate a conflict of Cardiocom's lead Counsel, Daniel McDonald of the Merchant & Gould firm related to a hearing scheduled in Minnesota.

The requested continuance shall not otherwise affect scheduling issues for the case. No previous extension of Bosch's reply deadline has been requested or granted. The parties had previously requested to move the hearing date, but did not foresee the conflict of the new date.

IT IS SO STIPULATED, through counsel of record:

PURSUANT TO STIPULATION, IT IS SO ORDERED that Bosch, Inc. shall have until February 2, 2017 to file its Reply regarding Bosch's Motion to Lift Stay (Dkt. 171) and the hearings for that motion and the Case Management Conference are continued to March 2, 2017.

DECLARATION OF WILLIAM SCHULTZ IN SUPPORT OF JOINT STIPULATION TO EXTEND TIME TO REPLY REGARDING MOTION TO LIFT STAY AND CONTINUE HEARING DATE FOR MOTION AND CASE MANAGEMENT CONFERENCE

1. I am an attorney for Cardiocom, LLC in this matter. The statements made herein are based on my personal knowledge and on information made available to me in the course of my duties and responsibilities for Cardiocom, LLC.

2. I corresponded with Bas de Blank, counsel for Bosch, Inc. regarding the hearing date for Bosch's Motion to Lift Stay and the Case Management Conference, both of which are currently scheduled for February 23, 2017. I requested that Bosch agree to continue the hearing date one week to March 2, 2017 based on a conflict relating to a hearing in another case scheduled in Minnesota. Bosch's counsel agreed to continue the hearing to March 2, 2017.

3. Bosch has requested a one week extension of time to file its reply regarding Bosch's Motion to Lift Stay. Bosch's reply is currently due January 26, 2017. The extension would make Bosch's brief due February 2, 2017. Cardiocom does not oppose Bosch's request.

4. The requested continuance and extension shall not otherwise affect scheduling issues for the case.

5. The parties have not previously requested an extension for Bosch to file its reply regarding Bosch's Motion to Lift Stay. The parties previously requested to move the hearing date based on other conflicts. The current request would move the hearings back one week, from February 23, 2017 to March 2, 2017. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on January 25, 2017 at Minneapolis, MN.

ATTESTATION OF CONCURRENCE IN FILING

I Adam Alper, am the ECF User whose identification and password are being used to file this Joint Stipulation. In compliance with Local Rule 5-1(i)(3), I hereby attest that Bas de Blank of Orrick, Herrington & Sutcliffe LLP has concurred in this filing.