Filed: Jul. 16, 2014
Latest Update: Jul. 16, 2014
Summary: JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO RESPOND TO DEFENDANT LIPTON'S MOTION TO DISMISS AND MOTION TO STRIKE BETH LABSON FREEMAN, District Judge. Plaintiff James McGibney, an individual, and ViaView, Inc., a corporation (collectively, "Plaintiffs"), together with Defendant Lane Lipton ("Defendant"), by and through counsel (collectively, the "Parties"), submit the following joint stipulation and proposed order pursuant to Local Rule 6-2. In support thereof, Plaintiffs' co
Summary: JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO RESPOND TO DEFENDANT LIPTON'S MOTION TO DISMISS AND MOTION TO STRIKE BETH LABSON FREEMAN, District Judge. Plaintiff James McGibney, an individual, and ViaView, Inc., a corporation (collectively, "Plaintiffs"), together with Defendant Lane Lipton ("Defendant"), by and through counsel (collectively, the "Parties"), submit the following joint stipulation and proposed order pursuant to Local Rule 6-2. In support thereof, Plaintiffs' cou..
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JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO RESPOND TO DEFENDANT LIPTON'S MOTION TO DISMISS AND MOTION TO STRIKE
BETH LABSON FREEMAN, District Judge.
Plaintiff James McGibney, an individual, and ViaView, Inc., a corporation (collectively, "Plaintiffs"), together with Defendant Lane Lipton ("Defendant"), by and through counsel (collectively, the "Parties"), submit the following joint stipulation and proposed order pursuant to Local Rule 6-2. In support thereof, Plaintiffs' counsel Jason S. Leiderman declares as follows:
1. In response to the Complaint in this case, Defendant Lane Lipton filed a Motion to Dismiss and a Special Motion to Strike Pursuant to Cal. Civ. Proc. Sec. 425.16 on July 3, 2014 ("Pending Motions"). (See Docket Nos. 15, 16.) The hearing date for the Pending Motions is set for September 18, 2014. Plaintiffs' response to the Pending Motions is set for July 17, 2014.
2. Plaintiffs' counsel was out of the country from June 4, 2014 until July 8, 2014. The month-long hiatus has created a backlog of work not just in this case, but other cases in which counsel is attorney of record.
3. On July 10, 2014, Plaintiffs' counsel conferred with Defendant's counsel regarding an extension of time to respond to the Pending Motions. Defendant's Counsel has agreed to extend the response date for the Pending Motions two weeks to July 31, 2014.
4. The court has not modified any other time limits in this case to this date.
5. The court has scheduled a case management conference for November 20, 2012, with a case management statement due a week prior. (See Docket No. 14.)
6. Extending the time to respond to Defendant's motions does not affect the court's case management schedule or any other schedule set by the court.
7. This stipulation shall not be considered a waiver of any claims or defenses of either party.
THEREFORE, the parties request the court accept the parties' stipulation and enter an Order extending Plaintiffs' time to respond to Defendant's motions until July 31, 2014.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
