BrowserCam, Inc. v. Gomez, Inc.

Filing 20

STIPULATION AND ORDER TO CONTINUE THE INITIAL CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES. Signed by Judge Alsup on September 5, 2008. (whalc1, COURT STAFF) (Filed on 9/5/2008)

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1 2 3 4 5 6 7 8 9 Wilmer Cutler Pickering Hale and Dorr LLP WILMER CUTLER PICKERING HALE AND DORR LLP Jonathan A. Shapiro (SBN: 257199) jonathan.shapiro@wilmerhale.com Michael A. Mugmon (SBN: 251958) michael.mugmon@wilmerhale.com 1117 S. California Avenue Palo Alto, CA 94304 Tel. (650) 858-6000 Fax. (650) 858-6100 Attorneys for Defendant GOMEZ, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION BROWSERCAM, INC., Plaintiff, vs. GOMEZ, INC., Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. C-08-2959-WHA STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE INITIAL CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES 10 11 1117 California Avenue Palo Alto, CA 94304 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 The Parties to this action stipulate and agree, by and through their undersigned counsel of record, as follows: WHEREAS, Plaintiff's complaint was filed Friday, June 13, 2008, and Defendant Gomez, Inc. was served with the complaint on Tuesday, June 17, 2008; WHEREAS, Defendant filed its Motion to Dismiss or Transfer on Tuesday, July 22, 2008; WHEREAS, the hearing before the Court on Defendant's Motion to Dismiss or Transfer is currently scheduled for Thursday, September 25, 2008 at 8:00 a.m.; WHEREAS, the Initial Case Management Conference ("CMC") for this action is currently scheduled for Thursday, September 18, 2008 at 11:00; Case No. C 08-2959-WHA STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE INITIAL CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES 1 2 3 4 5 6 7 8 9 Wilmer Cutler Pickering Hale and Dorr LLP WHEREAS, for reasons of judicial economy and efficiency, the Parties believe that the CMC currently scheduled for September 18, 2008, as well as the items associated with that CMC, should be deferred pending a ruling on Defendant's Motion to Dismiss or Transfer; NOW, THEREFORE, THE PARTIES HEREBY STIPULATE AND AGREE AND RESPECTFULLY REQUEST THAT THE COURT ENTER AN ORDER as follows: 1. The CMC currently scheduled for September 18, 2008, and other deadlines set forth in the Court's Order Setting Initial Case Management Conference and ADR Deadlines, shall be vacated; 2. The CMC shall be rescheduled, if necessary, to 30 days after the Court's order on 10 11 1117 California Avenue Palo Alto, CA 94304 Defendant's Motion to Dismiss or Transfer or such other date ordered by the Court, and all other associated deadlines shall be rescheduled in accordance with the new date for the CMC (i.e., each event shall precede the rescheduled CMC by the same period as the original deadlines preceded the original CMC date). IT IS SO STIPULATED. Respectfully submitted, DATED: August 27, 2008 WILMER CUTLER PICKERING HALE AND DORR LLP /S/ Michael A. Mugmon Michael A. Mugmon Attorney for Defendant GOMEZ, INC. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case No. C 08-2959-WHA STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE INITIAL CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES 1 2 3 4 5 6 7 8 9 Wilmer Cutler Pickering Hale and Dorr LLP DATED: August 27, 2008 ALLEN MATKINS LECK GAMBLE MALLORY & NATSIS /S/ Stephen S. Walters (with permission) Stephen S. Walters Three Embarcadero Center, 12th Floor San Francisco, CA 94111-4074 Tel: (415) 837-1515 Fax: (415) 837-1516 swalters@allenmatkins.com Attorney for Plaintiff BROWSERCAM, INC. SIGNATURE ATTESTATION 10 11 1117 California Avenue Palo Alto, CA 94304 I hereby attest that concurrence in the filing of this document has been obtained from each of the other signatories. I declare under penalty of perjury of the laws of the United States that the foregoing is true and correct. Executed this 27 day of August, 2008, at Palo Alto, California. /S/ Michael A. Mugmon, Esq. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case No. C 08-2959-WHA STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE INITIAL CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES 1 2 3 4 5 6 7 8 9 Wilmer Cutler Pickering Hale and Dorr LLP [PROPOSED] ORDER The Court hereby GRANTS the Parties' stipulated request and VACATES the deadlines ­ including the CMC currently scheduled for September 18, 2008 ­ set forth in the Court's Order Setting Initial Case Management Conference and ADR Deadlines pending a ruling on Defendant's Motion to Dismiss or Transfer; the CMC shall be rescheduled, if necessary, to 30 days after the Court's order on Defendant's Motion to Dismiss or Transfer or such other date ordered by the Court, and all other associated deadlines shall be rescheduled in accordance with the new date for the CMC (i.e., each event shall precede the rescheduled CMC by the same period as the original deadlines preceded the original CMC date). The CMC is hereby rescheduled to October 2, 2008, at 11:00AM. PURSUANT TO STIPULATION, IT IS SO ORDERED. UNIT ED S DISTRICT TE C TA 10 11 1117 California Avenue Palo Alto, CA 94304 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case No. C 08-2959-WHA US1DOCS 6798039v1 RT U O S N F D IS T IC T O R STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE INITIAL CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES A LI FO September 5, 2008. DATED: ____________________________ lsup ___________________________________ illiam A Judge W William H. Alsup United States District Court Judge ER C R NIA O IT IS S ORDER ED NO RT H

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