Federal Trade Commission v. Nextclick Media LLC et al

Filing 36

STIPULATION AND ORDER EXTENDING DEADLINE FOR FILING RESPONSIVE PLEADINGS to and including 2/2/2009 re [doc #35] filed by Federal Trade Commission. The case management conference currently scheduled for 1/22/2009 shall be rescheduled to 3/26/2009 at 3:30 PM. Joint statement shall be due 3/16/2009. Signed by Judge Vaughn R Walker on 12/1/2008. (cgk, COURT STAFF) (Filed on 12/1/2008)

Case 3:08-cv-01718-VRW

Document 35

Filed 11/21/2008

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WILLIAM BLUMENTHAL General Counsel JANICE L. CHARTER Colo. Bar No. 12750 DAVID M. NEWMAN Cal. Bar No. 54218 THOMAS DAHDOUH N.Y. Bar No. 2222370 Federal Trade Commission 901 Market Street, Suite 570 San Francisco, CA 94103 Phone [phone]/ Fax [phone] [e-mail]; [e-mail]; [e-mail] ATTORNEYS FOR PLAINTIFF FEDERAL TRADE COMMISSION UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

FEDERAL TRADE COMMISSION, Plaintiff, Case No. C08-1718-VRW v. NEXTCLICKMEDIA, LLC, et al., Defendants. STIPULATION FOR ORDER EXTENDING DEADLINE FOR FILING RESPONSIVE PLEADINGS AND PROPOSED ORDER

WHEREAS, Defendants NextClickMedia, LLC's, Next Internet, LLC's, Kenneth Chan's and Albert Chen's (collectively, "Defendants") response to Plaintiff Federal Trade Commission's (the "FTC") Complaint is currently due on Monday, December 1, 2008; WHEREAS, the parties to this action have continued to exchange information and proposed settlement provisions with the intention of exploring the possibility of settlement of this matter; WHEREAS, the FTC is willing to extend the time for Defendants to file their responses to Plaintiff's Complaint in order to focus on settlement discussions; and WHEREAS the parties believe that additional time will increase the likelihood that they Case No. C08-1718-VRW ­ Stip. Extending Deadline for Responsive Pleadings Page 1

Case 3:08-cv-01718-VRW

Document 35

Filed 11/21/2008

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will be able to reach a settlement of this matter; NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the FTC and Defendants, through their respective counsel, that Defendants' time to move, answer or otherwise respond to the Complaint shall be and hereby is extended to and including February 2, 2009; and IT IS FURTHER STIPULATED that the Case Management Conference, currently scheduled for January 22, 2009, at 3:30 p.m., be rescheduled to March 26, 2009, at 3:30 p.m., and that the date for filing the Case Management Statement be extended to March 16, 2009.

Dated: 11/21/08

/s/_________________________________ MICHAEL C. LYNCH KELLEY DRYE & WARREN, LLP ATTORNEY FOR DEFENDANTS /s/_________________________________ JANICE L. CHARTER DAVID M. NEWMAN THOMAS N. DAHDOUH ATTORNEYS FOR PLAINTIFF

Dated: 11/21/08 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED. 12/1/2008 Dated: _____________________

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