Filed: Dec. 20, 2012
Latest Update: Dec. 20, 2012
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT AND RESET INITIAL CASE DEADLINES MARIA-ELENA JAMES, Magistrate Judge. Pursuant to Local Rules 6-1(b) and 6-2(a), and subject to the Court's approval, Defendant Grass Valley USA, LLC ("Grass Valley") and Plaintiff Technology Licensing Corporation ("TLC"), by and through their respective counsel of record, hereby stipulate as follows: WHEREAS, TLC served its Complaint for Patent Infringement (the "Complaint") on December 3,
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT AND RESET INITIAL CASE DEADLINES MARIA-ELENA JAMES, Magistrate Judge. Pursuant to Local Rules 6-1(b) and 6-2(a), and subject to the Court's approval, Defendant Grass Valley USA, LLC ("Grass Valley") and Plaintiff Technology Licensing Corporation ("TLC"), by and through their respective counsel of record, hereby stipulate as follows: WHEREAS, TLC served its Complaint for Patent Infringement (the "Complaint") on December 3, ..
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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT AND RESET INITIAL CASE DEADLINES
MARIA-ELENA JAMES, Magistrate Judge.
Pursuant to Local Rules 6-1(b) and 6-2(a), and subject to the Court's approval, Defendant Grass Valley USA, LLC ("Grass Valley") and Plaintiff Technology Licensing Corporation ("TLC"), by and through their respective counsel of record, hereby stipulate as follows:
WHEREAS, TLC served its Complaint for Patent Infringement (the "Complaint") on December 3, 2012;
WHEREAS, the Court issued its Order Setting Initial Case Management Conference and ADR Deadlines on November 29, 2012 (the "Scheduling Order");
WHEREAS, Grass Valley currently has until December 24, 2012 to answer or otherwise respond to TLC's Complaint (Declaration of Vicki S. Veenker (the "Veenker Declaration"), filed concurrently herewith, at ¶2);
WHEREAS, the parties have stipulated, pending approval of the Court, to an additional 60 days for Grass Valley to answer or respond to TLC's Complaint, enlarging the time for response up to and including February 22, 2013 (Veenker Declaration, at ¶4); and
WHEREAS, because a 60-day extension would cause Grass Valley's response to be due six days before the Initial Case Management Conference and after all other deadlines in the Court's Scheduling Order, the parties have further stipulated to a 29-day extension of time of the deadlines set by the Court's Scheduling Order (Veenker Declaration, at ¶5).
NOW, THEREFORE, the parties, by and through their respective counsel, stipulate as follows:
1. Grass Valley's time to answer or otherwise respond to TLC's Complaint shall be extended 60 days to February 22, 2013.
2. The parties' last day to meet and confer regarding initial disclosures, early settlement, ADR process, and discovery plan; to file ADR certification; and to file either Stipulation to ADR Process or Notice of Need for ADR Phone Conference shall be extended 29 days to Friday, March 8, 2013.
3. The parties' last day to file the Rule 26(f) Report, complete initial disclosures or state objections in that Rule 26(f) Report and file a Case Management Statement per the Court's Standing Order re Contents of Joint Case Management Statements shall be extended 29 days to Friday, March 22, 2013.
4. The Initial Case Management Conference shall be rescheduled by the Court to a date on or after Friday, March 29, 2013.
ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
GENERAL ORDER 45 X.B. — ATTESTATION
I, Vicki Veenker, am the ECF User whose ID and password are being used to file this STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT. In compliance with General Order 45, X.B., I hereby attest that other counsel whose e-signature appears on the foregoing signature page has concurred with this filing.
