Entrepreneur Media Inc v. American City Business Journals Inc et al

Filing 11

Second STIPULATION Extending Time to Answer the complaint as to American City Business Journals Inc answer now due 7/1/2011, re Complaint - (Discovery), Complaint - (Discovery) 1 filed by defendant American City Business Journals Inc.(Sullivan, Sean)

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DAVIS WRIGHT TREMAINE LLP
865 S. FIGUEROA ST.
SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
TELEPHONE [phone]
FAX [phone]

JAMES D. NGUYEN (State Bar No. 179370)
[e-mail]
6 SEAN M. SULLIVAN (State Bar No. 229104)
[e-mail]
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Attorneys for Defendant
9 AMERICAN CITY BUSINESS JOURNALS, INC.
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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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14 ENTREPRENEUR MEDIA, INC., a

California corporation,

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Plaintiff,
vs.
AMERICAN CITY BUSINESS

18 JOURNALS, INC., a Delaware

corporation; and DOES 1-10,

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Defendants.

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Case No. Case No. 11-cv-00722-JVS-AN
SECOND STIPULATION TO
EXTEND TIME TO RESPOND TO
INITIAL COMPLAINT BY NOT
MORE THAN 30 DAYS
(L.R. 8-3)

Complaint Served: May 12, 2011
Current Response Date: June 17, 2011
New Response Date: July 1, 2011

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SECOND STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT
DWT 17375261v2 0068845-000004

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On May 11, 2011, plaintiff Entrepreneur Media, Inc. (“EMI”) filed the

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Complaint in this action and, on May 12, 2011, duly served the Complaint and

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Summons on defendant American City Business Journals, Inc. (“ACBJ”). Thus,

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ACBJ’s response to the Complaint was originally due on June 2, 2011.

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On May 31, 2011, the parties filed a stipulation to extend the deadline to
respond to the Complaint by 15 days, to June 17, 2011. (Dkt. No. 8.)
EMI has now agreed to grant to ACBJ an additional 14 days to respond to the
Complaint.
With this second extension, the total amount of extension time granted for
ACBJ to respond to the complaint still remains under 30 days.
THEREFORE, EMI and ACBJ, by and through their respective attorneys, do
hereby stipulate and agree as follows:

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ACBJ shall have until July 1, 2011, to respond to the Complaint.

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This stipulation is without prejudice to ACBJ’s right to seek, by stipulation or

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otherwise, any further extensions of time to respond to the Complaint that may be

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appropriate.

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IT IS SO STIPULATED.
Dated: June 15, 2011

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DAVIS WRIGHT TREMAINE LLP
By:

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/s/ Sean M. Sullivan
James D. Nguyen
Sean M. Sullivan
Attorneys for Defendant
AMERICAN CITY BUSINESS
JOURNALS, INC.

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Dated: June 15, 2011

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LATHAM & WATKINS LLP
By:

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Perry J. Viscounty
Jennifer L. Barry
Sean P. McClure

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Attorneys for Plaintiff
ENTREPRENEUR MEDIA, INC.

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1
SECOND STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT
DWT 17375261v2 0068845-000004

DAVIS WRIGHT TREMAINE LLP
865 S. FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
[phone]
Fax: [phone]