STIPULATION REGARDING EXTENSION OF TIME FOR PLAINTIFF TO RESPOND TO DEFENDANT'S MOTION TO DISMISS; AND TO REPLY TO ITS MOTION TO ENJOIN ROLLER CLUTCH FROM PROSECUTING CASE AGAINST DEFENDANT BEFORE THE EASTERN DISTRICT TO TEXAS

(Third Request for Extension to Respond to Motion to Dismiss)

(Fourth Request for Extension to Reply to Its Motion to Enjoin Roller Clutch)

GLORIA M. NAVARRO, Chief District Judge.

Pursuant to Fed. R. Civ. P. 6(b)(1)(A), Local Rules 6-1 and 6-2, Plaintiff JS Products, Inc. ("JS Products" or "Plaintiff") has requested, and Defendant Roller Clutch Tools, LLC ("Roller Clutch" or "Defendant") has agreed to, a two week extension of time, until February 2, 2018, for Plaintiff to file its Response to Defendant's Motion to Dismiss for Lack of Personal Jurisdiction Under Fed. R. Civ. P. 12(b)(2) and Improper Venue Under Fed. R. Civ. P. 12(b)(3). (ECF No. 30, "Motion"). This is the Parties' third request for an extension of the deadline to oppose the Motion. The Motion was originally filed on December 15, 2017 and the opposition is currently scheduled to be due on or before January 19, 2018.

Further, Defendant has also agreed to, a two week extension of time, until February 2, 2018, for Plaintiff to file its Reply to Its Motion to Enjoin Roller Clutch Tools, LLC from Prosecuting its Case Against Defendant before the United States District Court for the Eastern District of Texas. (ECF No. 07, "Motion"). This is the Parties' fourth request for an extension of the deadline to oppose the Motion. The Motion was originally filed on October 20, 2017, the Opposition (ECF No. 29, "Opposition") was filed December 15, 2017 and the Reply is currently scheduled to be due on or before January 19, 2018.

Good cause exists for this Court to grant this final extension because the Parties have reached an agreement in principle that settles all matters in controversy between them. Since submitting the last request for a time extension, the parties have exchanged several drafts of a comprehensive settlement agreement and are making progress toward reaching mutually agreeable language for several provisions in the agreement. The Parties respectfully and jointly request that this Court grant the requested extension to allow the parties to devote their full attention to finalizing the agreement, which will result in a dismissal stipulation being filed with the Court, and will moot the pending motions. The parties are amenable to a status conference before the Court, should it desire a further update on the status of drafting a final, comprehensive settlement agreement.

Accordingly, the Parties hereby stipulate that Plaintiff has until February 2, 2018 to file its Opposition to Defendant Roller Clutch's Motion to Dismiss for Lack of Personal Jurisdiction Under Fed. R. Civ. P. 12(b)(2) and Improper Venue Under Fed. R. Civ. P. 12(b)(3); and to Reply to Its Motion to Enjoin Roller Clutch Tools, LLC from Prosecuting its Case Against the Defendant in the matter before the United States District Court for the Eastern District of Texas.

ORDER

IT IS SO ORDERED.