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

Filing 13

Third STIPULATION for Extension of Time to File Answer to July 15, 2011 re Complaint - (Discovery), Complaint - (Discovery) 1 filed by defendant American City Business Journals Inc. (Attachments: # 1 Proposed Order)(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.

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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
THIRD STIPULATION EXTENDING
TIME TO RESPOND TO INITIAL
COMPLAINT BY 14 DAYS
(L.R. 8-3)

Complaint Served: May 12, 2011
Current Response Date: July 1, 2011
New Response Date: July 15, 2011

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THIRD STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT
DWT 17511294v1 0068845-000004

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This stipulation is entered by and between plaintiff Entrepreneur Media, Inc.

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(“EMI”) and defendant American City Business Journals, Inc. (“ACBJ”) through

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their respective counsel of record, with reference to the following facts:

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EMI filed the Complaint in this action on May 11, 2011, and served the

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Complaint and Summons on ACBJ on May 12, 2011. Thus, ACBJ’s response to the

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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 for
ACBJ to respond to the Complaint by 15 days, to June 17, 2011. (Dkt. No. 8.)

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On June 15, 2011, the parties filed a second stipulation to extend the deadline

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for ACBJ to respond to the Complaint by an additional 14 days, with the total

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extension of time granted for ACBJ to respond to the complaint still under 30 days.

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(Dkt. No. 11.)

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The parties have been engaged in settlement discussions in an attempt to

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resolve this matter. EMI sent ACBJ an initial draft of a settlement agreement on

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June 14, 2011, to which ACBJ responded with comments on June 22, 2011. EMI

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sent a revised draft of the settlement agreement to ACBJ on June 29, 2011, which

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ACBJ is in the process of reviewing. To provide the parties sufficient time to

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finalize a resolution, counsel for the parties have agreed to extend the deadline for

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ACBJ to respond to the Complaint by two weeks.

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THIRD STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT
DWT 17511294v1 0068845-000004

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

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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 15, 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.

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Dated: June 30, 2011

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DAVIS WRIGHT TREMAINE LLP
By:

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Attorneys for Defendant
AMERICAN CITY BUSINESS
JOURNALS, INC.

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/s/ Sean M. Sullivan
James D. Nguyen
Sean M. Sullivan

Dated: June 30, 2011

LATHAM & WATKINS LLP

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By:

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Perry J. Viscounty
Jennifer L. Barry
Sean P. McClure
Attorneys for Plaintiff
ENTREPRENEUR MEDIA, INC.

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THIRD STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT
DWT 17511294v1 0068845-000004

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