MGA Entertainment Inc v. Mattel Inc et al

Filing 10

Joint STIPULATION to Exceed Page Limitation as to Mattel, Inc.'s and Robert A. Eckert's Notice of Motion and Motion to Dismiss MGA Entertainment, Inc.'s Complaint filed by Defendant Mattel Inc. (Attachments: # 1 Proposed Order)(Proctor, Brett)

MGA Entertainment Inc v. Mattel Inc et al

Doc. 10

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP John B. Quinn (Bar No. 090378) 2 ([e-mail]) Michael T. Zeller (Bar No. 196417) 3 ([e-mail]) 865 South Figueroa Street, 10th Floor 4 Los Angeles, California 90017-2543 5 Telephone: [phone] Facsimile: [phone] 6 Attorneys for Mattel, Inc. and Robert A. 7 Eckert 8 UNITED STATES DISTRICT COURT 9 10 CENTRAL DISTRICT OF CALIFORNIA SOUTHERN DIVISION CASE NO. CV 11-1063 DOC (RNBx) Hon. David O. Carter

11 MGA ENTERTAINMENT, INC., a California corporation, 12 Plaintiff, 13 vs. 14 MATTEL, INC., a Delaware 15 corporation, et al., and ROBERT A. ECKERT 16 Defendants. 17 18 19 20 21 22 23 24 25 26 27 28
00505.07975/4010590.1

STIPULATION TO EXTEND PAGE LIMIT AND SET BRIEFING SCHEDULE RE: MATTEL, INC.'S MOTION TO DISMISS

Case No. CV 11-01063 DOC (RNBx) STIPULATION Dockets.Justia.com

1

WHEREAS, MGA Entertainment, Inc. ("MGA") filed Case No. CV 11-1063

2 DOC (RNBx) against Mattel, Inc. and Robert A. Eckert (collectively "Mattel") on 3 February 3, 2011; 4 5 2011; 6 WHEREAS, Local Rule 11-6 states that "[n]o memorandum of points and 7 authorities, pre-trial brief, trial brief, or post-trial brief shall exceed 25 pages in 8 length, excluding indices and exhibits, unless permitted by order of the judge"; 9 WHEREAS, given the complexity and importance of the issues raised by 10 Mattel's motion to dismiss, Mattel has requested, and MGA does not object to, 20 11 additional pages to respond to MGA's complaint; 12 WHEREAS, Local Rules 7-9 and 7-10 state that MGA's response to Mattel's 13 motion to dismiss shall be filed 21 days before the hearing date and Mattel's reply 14 shall be filed 14 days before the hearing date; 15 17 WHEREAS, MGA has requested an extended briefing schedule to respond to WHEREAS, the parties have agreed that MGA's response to Mattel's motion 16 the issues raised by Mattel's motion to dismiss; 18 to dismiss shall be filed by April 29, 2011, Mattel's reply shall be filed by May 20, 19 2011, and the matter shall be heard on June 6, 2011, or such other date as the Court 20 may select; 21 NOW, THEREFORE, by and through their respective counsel of record, the 22 Parties hereby stipulate and agree, subject to approval by the Court, that (1) Mattel's 23 motion to dismiss and MGA's response thereto shall be no longer than 45 pages in 24 length; (2) MGA's response to Mattel's motion to dismiss shall be filed by April 29, 25 2011; (3) Mattel's reply shall be filed by May 20, 2011; and (4) the hearing date 26 shall be scheduled for June 6, 2011. 27 28
00505.07975/4010590.1

WHEREAS, Mattel is required to respond to MGA's complaint by March 17,

IT IS SO STIPULATED. -1Case No. CV 11-01063 DOC (RNBx) STIPULATION

1 2 DATED: March 17, 2011 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
00505.07975/4010590.1

QUINN EMANUEL URQUHART & SULLIVAN, LLP By /s/ Michael T. Zeller Michael T. Zeller Attorneys for Mattel, Inc. and Robert A. Eckert

DATED: March 17, 2011

BLECHER & COLLINS, P.C. By /s/ Maxwell M. Blecher Maxwell M. Blecher Attorneys for MGA, Entertainment, Inc.

-2-

Case No. CV 11-01063 DOC (RNBx) STIPULATION