Champion Laboratories, Inc. v. Parker-Hannifin Corp et al

Filing 45

STIPULATION For an Extension of Time 1) for Plaintiff to File Its Amended Complaint; 2) For Defendants to Respond Thereto; and 3) For the Date of Scheduling Conference and ORDER Thereon, signed by Judge Oliver W. Wanger on 5/25/2011. (Amended Complaint due by 6/16/2011, Response due by 7/15/2011, Initial Scheduling Conference CONTINUED to 8/25/2011 at 08:15 AM in Courtroom 3 (OWW) before Judge Oliver W. Wanger.) (Gaumnitz, R)

1 MARK D. MILLER (California Bar No. 116349) ([e-mail])
MARCUS N. DiBUDUO (California Bar No. 258684) (mdibuduo@ sierraiplaw.com)
2 SIERRA IP LAW, PC
A Professional Corporation
3 6780 N. West Avenue, Suite 102
P. O. Box 5637
4 Fresno, California 93755-5637
Telephone: [phone]
5 Facsimile: [phone]
6 BRIAN W. LEWIS (Illinois Bar No. 6190792)
PAUL OLSZOWKA (Illinois Bar No. 6291267)
7 MARK NAHNSEN (Illinois Bar No. 6271361)
BARNES & THORNBURG LLP
One North Wacker Drive, Suite 4400
8 Chicago, Illinois 60606-2833
Telephone: [phone]
9 Facsimile: [phone]
10 Attorneys for Plaintiff
CHAMPION LABORATORIES, INC.
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION
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14 CHAMPION LABORATORIES, INC., a
Delaware Corporation,
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Plaintiff,
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v.
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PARKER-HANNIFIN CORPORATION,
18 including its Racor Division, and PARKER
INTANGIBLES, LLC,
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Defendants.
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Case No. 1:10-cv-02371 OWW DLB
STIPULATION FOR AN EXTENSION
OF TIME (1) FOR PLAINTIFF TO FILE
ITS AMENDED COMPLAINT; (2) FOR
DEFENDANTS TO RESPOND
THERETO; AND (3) FOR THE DATE
OF SCHEDULING CONFERENCE
AND ORDER THEREON

WHEREAS, on May 17, 2011, the Court issued its Memorandum Opinion
regarding Defendants’ Motion to Dismiss (“Order”);
WHEREAS, pursuant to said Order Plaintiff CHAMPION LABORATORIES,
INC. (“Champion”) currently has until June 6, 2011 within which to file an amended complaint;
WHEREAS,

pursuant

to

said

Order

Defendants

PARKER-HANNIFIN

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CORPORATION, and PARKER INTANGIBLES, LLC (collectively “Parker”) have until June

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26, 2011 within which to respond to Plaintiff’s amended complaint;

LAW OFFICES

Sierra IP Law, PC
A PROFESSIONAL CORPORATION
6780 N. W EST AVE., STE. 102
P. O. Box 5637
FRESNO, CA 93755-5637

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STIPULATION FOR AN EXTENSION OF TIME (1) FOR PLAINTIFF TO FILE ITS AMENDED COMPLAINT; (2) FOR DEFENDANTS
TO RESPOND THERETO; AND (3) FOR THE DATE OF SCHEDULING CONFERENCE AND ORDER THEREON

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WHEREAS, Plaintiff and Defendants wish to extend the time for Plaintiff to file

2 its amended complaint and for Defendants to respond thereto; and
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WHEREAS, the pleadings will not be final as of June 22, 2011, which is the date

4 currently set for the Scheduling Conference in this matter, such that said Conference should be
5 continued to a later date.
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NOW, THEREFORE, IT IS HEREBY STIPULATED, CONSENTED, AND

7 AGREED TO by and between the parties through their respective counsel, as follows:
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(1) that the time for Plaintiff to file its amended complaint shall be extended until
and including June 16, 2011; and
(2) That the time for Defendants to respond to Plaintiff’s amended complaint
shall be extended until and including July 15, 2011.
IT IS FURTHER STIPULATED, CONSENTED, AND AGREED TO by and

13 between the parties, that with the Court’s permission, the July 22, 2001 Scheduling Conference
14 date be vacated, and that the Scheduling Conference be rescheduled to August 25, 2011.
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DATED: May 25, 2011

Respectfully submitted,

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SIERRA IP LAW, PC
Mark D. Miller
Marcus N. DiBuduo

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BARNES & THORNBURG LLP
Brian W. Lewis
Paul Olszowka
Mark Nahnsen

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By:
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/s/
Paul Olszowka
Attorneys for Plaintiff,
CHAMPION LABORATORIES, INC.
Attorneys for Defendants

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- and -

LAW OFFICES

Sierra IP Law, PC
A PROFESSIONAL CORPORATION
6780 N. W EST AVE., STE. 102
P. O. Box 5637
FRESNO, CA 93755-5637

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STIPULATION FOR AN EXTENSION OF TIME (1) FOR PLAINTIFF TO FILE ITS AMENDED COMPLAINT; (2) FOR DEFENDANTS
TO RESPOND THERETO; AND (3) FOR THE DATE OF SCHEDULING CONFERENCE AND ORDER THEREON

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DATED: May 25, 2011

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Respectfully submitted,
CONNOLLY BOVE LODGE & HUTZ LLP

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/s/
Francis DiGiovanni

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Attorneys for Defendants
Parker-Hannifin Corporation and
Parker Intangibles LLC

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IT IS SO ORDERED.
Dated:

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May 25, 2011

/s/ Oliver W. Wanger
UNITED STATES DISTRICT JUDGE

DEAC_Signature-END:

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LAW OFFICES

Sierra IP Law, PC
A PROFESSIONAL CORPORATION
6780 N. W EST AVE., STE. 102
P. O. Box 5637
FRESNO, CA 93755-5637

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STIPULATION FOR AN EXTENSION OF TIME (1) FOR PLAINTIFF TO FILE ITS AMENDED COMPLAINT; (2) FOR DEFENDANTS
TO RESPOND THERETO; AND (3) FOR THE DATE OF SCHEDULING CONFERENCE AND ORDER THEREON

3