Adobe Systems Incorporated v. Norwood

Filing 46

ORDER GRANTING REQUEST TO CONTINUE MOTION HEARINGS (tf, COURT STAFF) (Filed on 4/20/2011)

1
2
3
4
5
6
7
8
9
10
11
12
13

J. Andrew Coombs (SBN 123881)
[e-mail]
Nicole L. Drey (SBN 250235)
[e-mail]
J. Andrew Coombs, A P. C.
517 East Wilson Avenue, Suite 202
Glendale, California 91206
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Plaintiff and Counter-Defendant
Adobe Systems Incorporated and Third-Party
Defendant Software & Information Industry
Association (erroneously identified as Counter-Defendant)
Michael L. Rodenbaugh (SBN 179059)
[e-mail]
Rodenbaugh Law
548 Market Street
San Francisco, California 94104
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Defendant, Counter-Claimant and
Third-Party Plaintiff Renee Norwood

14

UNITED STATES DISTRICT COURT

15

NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO)

16
17

Adobe Systems Incorporated,

18
19
20
21
22

Plaintiff,
v.
Renee Norwood, et al.,
Defendants.
ALL RELATED CLAIMS

23

)
)
)
)
)
)
)
)
)
)
)
)
)

Case No. C10-3564 SI
JOINT STIPULATION RE
CONTINUANCE OF HEARING DATE
ON PENDING MOTION TO DISMISS
AMENDED COUNTERCLAIMS

24

Plaintiff and Counter-Defendant Adobe Systems Incorporated (“Adobe”), Third-Party
25

Defendant Software & Information Industry Association (“SIIA”), and Defendant and Counter26

Claimant Renee Norwood (“Norwood”) (collectively the “Parties”), by and through their respective
27

counsel of record, hereby stipulate and agree as follows:
28
Adobe v. Norwood, et al.: Stipulation re Continuance

-1-

1

WHEREAS Norwood filed her Amended Counterclaims on or about March 18, 2011;

2

WHEREAS Adobe and the SIIA filed their Motion to Dismiss the Amended Counterclaims
3

(“Motion”) on or about April 8, 2011;
4

WHEREAS the Parties stipulate that any delay in filing the Motion has not caused
5

prejudice to Norwood and that Norwood waives any objections to the timeliness of the Motion, in
6

the event this stipulation is entered by the Court;
7

WHEREAS the hearing on the Motion is currently set for May 13, 2011;
8

WHEREAS counsel for Norwood has a familial obligation on May 13, 2011, such that he
9

cannot attend the hearing;
10

WHEREAS counsel for Norwood is currently preparing a motion to withdraw as counsel
11

due to Norwood’s unresponsiveness and lack of payment;
12

WHEREAS, if Norwood’s current counsel is granted leave to withdraw as counsel,
13

Norwood will need sufficient time to retain new counsel and/or prepare an opposition to the
14

Motion;
15

WHEREAS, alternatively, should counsel’s motion to withdraw not be granted, counsel
16

will need sufficient time to prepare an opposition to the Motion and is not available for hearing
17

prior to July 8, 2011;
18

WHEREAS the requested continuance will not affect any current Court deadlines; and
19

///
20
21

///
22
23

///
24
25

///
26
27

///
28
Adobe v. Norwood, et al.: Stipulation re Continuance

-2-

1

NOW, THEREFORE, Adobe, the SIIA, and Norwood stipulate and request the hearing on

2

Adobe and the SIIA’s Motion be continued until July 8, 2011, or a date thereafter acceptable with
3

the Court, with all briefing dates adjusted accordingly.
4

IT IS SO STIPULATED:
5
6

Dated: April 19, 2011

J. Andrew Coombs, A Professional Corp.

7

By: __/s Nicole L. Drey______________________
J. Andrew Coombs
Nicole L. Drey
Attorneys for Plaintiff and Counter-Defendant Adobe
Systems Incorporated and Third-Party Defendant
Software & Information Industry Association

8
9
10
11
12

Dated: April 19 , 2011

13

Rodenbaugh Law
By: __/s Michael L. Rodenbaugh_______________
Michael L. Rodenbaugh
Attorneys for Defendant and Counter-Claimant Renee
Norwood

14
15
16
17
18
19

[PROPOSED] ORDER
PURSUANT TO REQUEST, IT IS SO ORDERED.
4/19/11
DATED: _______________, 2011

20
21

Hon. Susan Illston
UNITED STATES DISTRICT JUDGE

22
23
24
25
26
27
28
Adobe v. Norwood, et al.: Stipulation re Continuance

-3-