MGA Entertainment Inc v. Mattel Inc et al

Filing 9

FIRST STIPULATION Extending Time to Answer the complaint as to All Defendants, filed by Defendant Mattel Inc. (Attachments: # 1 Proposed Order)(Proctor, Brett)

MGA Entertainment Inc v. Mattel Inc et al

Doc. 9

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)

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
00505.07975/3955574.2

Hon. David O. Carter

STIPULATION TO EXTEND TIME TO RESPOND TO INITIAL COMPLAINT IN CASE NO. 11-1063 BY NOT MORE THAN 30 DAYS (L.R. 8-3) Complaint Served: February 4, 2011 Current Response date: February 25, 2011 New Response date: March 17, 2011

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 WHEREAS, MGA served its summons and complaint on Mattel, Inc. on

5 February 4, 2011, and Mattel agreed to accept service on behalf of Mr. Eckert; 6 WHEREAS, Mattel is required to serve its answer and/or respond to MGA's

7 complaint by February 25, 2011, twenty-one days after service of the summons and 8 complaint; 9 WHEREAS, Mattel has requested and MGA has agreed to a twenty-day

10 extension in light of the number and importance of the issues to be raised; 11 WHEREAS, this is Mattel's first request to extend time to respond to the

12 initial complaint; 13 WHEREAS, Local Rule 8-3 states that "[i]f the stipulation . . . does not

14 extend the time [to respond to the initial complaint] for more than a cumulative total 15 of thirty (30) days from the date the response initially would have been due, the 16 stipulation need not be approved by the judge," but the parties nevertheless wished 17 to bring this stipulation to the Court's attention and seek the Court's approval; 18 NOW, THEREFORE, by and through their respective counsel of record, the

19 Parties hereby stipulate and agree, subject to approval by the Court, that Mattel's 20 answer and/or response to MGA's complaint in Case No. CV 11-1063 shall be due 21 on March 17, 2011. 22 23 24 25 26 27 28
00505.07975/3955574.2

IT IS SO STIPULATED.

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

1 DATED: February 15, 2011 2 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
00505.07975/3955574.2

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

DATED: February 15, 2011

BLECHER & COLLINS, P.C.

By /s/ Maxwell M. Blecher Maxwell M. Blecher Attorneys for MGA, Entertainment, Inc.

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