Next Innovation, LLC v. Visteon Corporation

Filing 11

JOINT STIPULATION AND ORDER TO EXTEND DEFENDANT'S TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT - Dft has until 4/23/9 to answer or otherwise respond to the complaint. Signed by Judge Joseph C. Spero on 03/23/09. (klh, COURT STAFF) (Filed on 3/23/2009)

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S ean P . D e B ru i n e (S B N 1 6 8 0 7 1 ) ALSTON & BIRD LLP T w o P al o A l t o S q u a r e 3 0 0 0 E l C am i n o R e al , S u i t e 4 0 0 P al o A l t o , C al i fo r n i a 9 4 3 0 6 T el ep h o n e: 6 5 0 - 8 3 8 -2 0 0 0 F acs i m i l e: 6 5 0 - 8 3 8 -2 0 0 1 s ea n . d eb ru i n e@ al s t o n . c o m Kirk T. Bradley (applying pro hac vice) ALSTON & BIRD LLP 101 South Tryon Street, Suite 4000 Charlotte, North Carolina 28280-4000 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant VISTEON CORPORATION

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION NEXT INNOVATION, LLC, Plaintiff, v. VISTEON CORPORATION, Defendant. ) Case No. 3:09-cv-00804-JCS ) ) JOINT STIPULATION AND [PROPOSED] ) ORDER TO EXTEND DEFENDANT'S ) TIME TO ANSWER OR OTHERWISE ) RESPOND TO PLAINTIFF'S COMPLAINT ) ) ) )

WHEREAS, Plaintiff NEXT INNOVATION, LLC ("Plaintiff") filed its Complaint against Defendant VISTEON CORPORATION ("Defendant") on February 24, 2009, and served it on Defendant on March 4, 2009; WHEREAS, Defendant is currently scheduled to answer or otherwise respond to the Complaint by March 24, 2009; WHEREAS, there have been no prior stipulations or requests for extension of time to respond to the Complaint; WHEREAS, counsel for Defendant recently was retained to represent Defendant in this action,
JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND DEFENDANT'S TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT

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Case No. 3:09-cv-00804-JCS

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and Defendant requires additional time to prepare its response to the Complaint; and WHEREAS, Plaintiff has agreed to extend the time for Defendant to answer or otherwise respond to the Complaint by thirty (30) days, up to and including April 23, 2009; NOW THEREFORE, pursuant to Civil Local Rule 6-1, the parties hereby stipulate and agree as follows: Defendant Visteon Corporation shall have until April 23, 2009 to answer or otherwise respond to Plaintiff's Complaint. DERGOSITS & NOAH LLP

Dated: March 20, 2009

By:

/s/ Michael E. Dergosits

Attorneys for Plaintiff NEXT INNOVATION, LLC

Dated: March 20, 2009

ALSTON + BIRD LLP

By:

/s/ Sean P. DeBruine

Attorneys for Defendant VISTEON CORPORATION THE FOREGOING STIPULATION IS APPROVED
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JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND DEFENDANT'S TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT

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Case No. 3:09-cv-00804-JCS

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UNITED STATES MAGISTRATE JUDGE
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pero

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DATED:

23 March ____, 2009

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AND IT IS SO ORDERED.

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NO

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CERTIFICATION OF CONCURRENCE I attest under penalty of perjury and pursuant to General Order No. 45 that concurrence in the filing of this document has been obtained from Michael E. Dergosits.

________/s/ Sean P. DeBruine

JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND DEFENDANT'S TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT

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Case No. 3:09-cv-00804-JCS