Gofron et al v. Picsel Technologies, Inc. et al

Filing 23

STIPULATION AND ORDER re 21 Stipulation filed by Lescip T Limited. Signed by Judge Edward M. Chen on 7/13/10. (bpf, COURT STAFF) (Filed on 7/13/2010)

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Gofron et al v. Picsel Technologies, Inc. et al Doc. 23 1 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP 2 3 4 5 6 A Limited Liability Partnership Including Professional Corporations STEVEN B. SACKS, Cal. Bar No. 98875 MARTIN WHITE, Cal. Bar No. 253476 Four Embarcadero Center, 17th Floor San Francisco, California 94111-4109 Telephone: 415-434-9100 Facsimile: 415-434-3947 E-Mail: ssacks@sheppardmullin.com mwhite@sheppardmullin.com 7 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP 8 9 10 11 A Limited Liability Partnership Including Professional Corporations EDWARD H. TILLINGHAST, III 30 Rockefeller Plaza, 24th Floor New York, New York 10112-2201 Telephone: 212-653-8700 Facsimile: 212-653-8701 E-Mail: etillinghast@sheppardmullin.com ADMINISTRATORS OF LESCIP T. LIMITED UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION Civil Action No. 3:09-CV-04041-EMC [Complaint Filed: August 31, 2009] STIPULATION EXTENDING DEFENDANT LESCIP T LIMITED'S TIME TO RESPOND TO COMPLAINT PURSUANT TO LOCAL RULE 6-1(a) ; ORDER Judge: Hon. Edward M. Chen Trial Date: None Set 12 Attorneys for Defendant 13 14 15 16 17 CARRIE GOFRON, J. WILLIAM VANKE, ASHWINI KUMAR, MATTHEW MIXON, 18 AND DULCE GONZALEZ, 19 20 v. Plaintiffs, 21 PICSEL TECHNOLOGIES, INC., LESCIP T LIMITED (formerly PICSEL 22 TECHNOLOGIES LIMITED), HAMSARD LIMITED, MASOOD JABBAR AND 23 IMRAN KHAND, 24 25 26 27 28 Defendants. W02-EAST:7BXL1\200320280.2 Civil Action No. 3:09-cv-04041-EMC STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT Dockets.Justia.com 1 2 action; 3 WHEREAS on August 31, 2009, Plaintiffs filed their original Complaint in this WHEREAS on May 21, 2010, Plaintiffs filed their First Amended Complaint, 4 pursuant to which they, inter alia, added defendant LESCIP T. LIMITED ("Lescip") to the 5 action; 6 WHEREAS Lescip is a UK-based company that entered into administration (the 7 "Administration") on July 15, 2009, and John Bruce Cartwright and Graham Frost were appointed 8 Joint Administrators of Lescip (the "Administrators"); 9 WHEREAS on June 16, 2010, the Administrators were allegedly served with the 10 First Amended Complaint; 11 WHEREAS if service is deemed proper, the due date for the Administrators of 12 Lescip to plead, answer or otherwise respond to the First Amended Complaint would have been on 13 or about July 7, 2010; 14 WHEREAS the Administrators of Lescip require additional time to evaluate the 15 First Amended Complaint and plead, answer or otherwise respond to the First Amended 16 Complaint; 17 WHEREAS the parties believe and agreed on July 7, 2010, that it is prudent, 18 desirable and efficient to extend the time for the Administrators of Lescip to respond to the First 19 Amended Complaint; 20 WHEREAS an extension of time until Tuesday, August 3, 2010 for the 21 Administrators of Lescip to plead, answer or otherwise respond to the First Amended Complaint 22 will not alter the date of any event or deadline already fixed by Court order in this action; 23 NOW THEREFORE, pursuant to Local Rule 6-1(a), it is hereby stipulated and 24 agreed by and between Plaintiffs and the Administrators of Lescip that: 25 The Administrators of Lescip shall have through to and including Tuesday, August 26 3, 2010 to plead, answer or otherwise respond to the First Amended Complaint in this action. 27 28 W02-EAST:7BXL1\200320280.2 -1- Civil Action No. 3:09-cv-04041-EMC STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT 1 This stipulation is entered into without waiver of any and all defenses available to 2 the Administrators of Lescip, including without limitation, lack of personal jurisdiction, improper 3 service and that commencing this action against Lescip is a violation of the moratorium in the 4 Administration, and is not a concession that service has been effected on Lescip or the 5 Administrators of Lescip. 6 IT IS SO STIPULATED 7 Dated: July 9, 2010 8 9 10 11 Attorneys for Defendant By /s/ Steven B. Sacks STEVEN B. SACKS SHEPPARD, MULLIN, RICHTER & HAMPTON LLP 12 13 Dated: July 9, 2010 14 15 16 17 18 UNIT ED LESCIP T. LIMITED CRAIG A. MARR, ATTORNEY AT LAW By /s/ Craig A. Marr CRAIG A. MARR Attorney for Plaintiffs 19 20 21 22 23 24 25 26 27 28 IT IS SO ORDERED: S ISTRIC ES D TC AT T dward M _________________ Judge E Edward M. Chen U.S. Magistrate Judge E R N . Chen F D IS T IC T O R A C W02-EAST:7BXL1\200320280.2 LI FO R NIA O IT IS S ORDER ED RT U O Civil Action No. 3:09-cv-04041-EMC NO RT H -2- STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT

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