Implicit Networks, Inc. v. Juniper Networks, Inc.
Filing
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ORDER Pursuant to the stipulation of the parties, it is hereby ORDERED that that Juniper will be deemed to have timely filed any request for costs and/or fees in this action that is submitted on or before April 8, 2013.. Signed by Judge Susan Illston on 3/26/13. (tfS, COURT STAFF) (Filed on 3/27/2013)
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IRELL & MANELLA LLP
Morgan Chu (CA Bar No. 70446)
(mchu@irell.com)
Jonathan S. Kagan (CA Bar No. 166039)
(jkagan@irell.com)
1800 Avenue of the Stars, Suite 900
Los Angeles, California 90067-4276
Telephone: (310) 277-1010
Facsimile: (310) 203-7199
David C. McPhie (CA Bar No. 231520)
(dmcphie@irell.com)
Douglas J. Dixon (CA Bar No. 275389)
(ddixon@irell.com)
840 Newport Center Drive, Suite 400
Newport Beach, California 92660-6324
Telephone: (949) 760-0991
Facsimile: (949) 760-5200
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Attorneys for Defendant
JUNIPER NETWORKS, INC.
Additional Attorneys Listed on Signature Page
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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
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IMPLICIT NETWORKS, INC.,
Case No. C 10-4234 SI
Plaintiff,
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v.
JUNIPER NETWORKS, INC.,
STIPULATION REGARDING
DEADLINE TO REQUEST COSTS
AND/OR FEES AND
[PROPOSED] ORDER
Defendant.
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STIPULATION REGARDING DEADLINE TO
REQUEST COSTS AND/OR FEES AND
[PROPOSED] ORDER
Case No. C 10-4234 SI
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Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiff Implicit Networks, Inc.
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("Implicit") and Defendant Juniper Networks, Inc. ("Juniper") hereby stipulate through their
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respective counsel of record as follows:
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WHEREAS, on March 13, 2013, this Court granted Juniper's motions for summary
judgment on invalidity and non-infringement (see Dkt. No. 205);
WHEREAS, on March 14, 2013, this Court entered Judgment in favor of Juniper
(see Dkt. No. 206);
WHEREAS, Federal Rule of Civil Procedure 54(d)(2)(B) and Civil Local Rule
54-5(a) ordinarily would require Juniper to file for costs and fees no later than March 28,
2013 (14 days after the entry of judgment); and
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WHEREAS, the parties believe that providing for a modest extension of this
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deadline would facilitate ongoing discussions between the parties and potentially conserve
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judicial resources;
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NOW THEREFORE the parties through their undersigned counsel, hereby stipulate
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and request that the Court grant, pursuant to Local Rule 6-2, that Juniper will be deemed to
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have timely filed any request for costs and/or fees submitted on or before April 8, 2013.
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IT IS SO STIPULATED.
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March 22, 2012
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/s/ David C. McPhie
DAVID C. MCPHIE (CA Bar No. 231520)
dmcphie@irell.com
DOUGLAS J. DIXON (CA Bar No. 275389)
ddixon@irell.com
Irell & Manella LLP
840 Newport Center Drive, Suite 400
Newport Beach, CA 92660-6324
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MORGAN CHU (CA Bar No. 70446)
mchu@irell.com
JONATHAN S. KAGAN (CA Bar No. 166039)
jkagan@irell.com
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Respectfully and jointly submitted,
STIPULATION REGARDING DEADLINE TO
REQUEST COSTS AND/OR FEES AND
[PROPOSED] ORDER
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Case No. C 10-4234 SI
IRELL & MANELLA LLP
1800 Avenue of the Stars, Suite 900
Los Angeles, CA 90067-4276
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Attorneys for Defendant
JUNIPER NETWORKS, INC.
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/s/ Spencer Hosie
SPENCER HOSIE (CA Bar No. 101777)
shosie@hosielaw.com
DIANE S. RICE (CA Bar No. 118303)
drice@hosielaw.com
HOSIE RICE LLP
Transamerica Pyramid, 34th Floor
600 Montgomery Street
San Francisco, CA 94111
(415) 247-6000 Tel.
(415) 247-6001 Fax
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Attorneys for Plaintiff
IMPLICIT NETWORKS, INC.
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STIPULATION REGARDING DEADLINE TO
REQUEST COSTS AND/OR FEES AND
[PROPOSED] ORDER
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Case No. C 10-4234 SI
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I hereby attest pursuant to General Order 45.X.B. that concurrence in the electronic
filing of this document has been obtained from the other signatories.
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/s/ David C. McPhie
DATED: March 22, 2013
David C. McPhie
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STIPULATION REGARDING DEADLINE TO
REQUEST COSTS AND/OR FEES AND
[PROPOSED] ORDER
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Case No. C 10-4234 SI
ORDER
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Pursuant to the stipulation of the parties, it is hereby ORDERED that that Juniper
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will be deemed to have timely filed any request for costs and/or fees in this action that is
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submitted on or before April 8, 2013.
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PURSUANT TO STIPULATION IT IS SO ORDERED.
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Dated: March ____, 2013
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_____________________________
Honorable Susan Illston
United States District Judge
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[PROPOSED] ORDER ON STIPULATION
REGARDING DEADLINE TO REQUEST COSTS
AND/OR FEES
Case No. C 10-4234 SI
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
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4 IMPLICIT NETWORKS, INC.,
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Plaintiff,
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Case No. C 10-4234 SI
v.
7 JUNIPER NETWORKS, INC.,
Defendant.
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DECLARATION OF DAVID C. McPHIE IN SUPPORT OF
STIPULATION REGARDING DEADLINE TO REQUEST COSTS AND/OR FEES
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I, David C. McPhie, hereby declare as follows:
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I am attorney with the law firm of Irell & Manella LLP, counsel for defendant
14 Juniper Networks, Inc. (“Juniper”) in this matter. I am a member in good standing of the State Bar
15 of California and am admitted to practice before this Court. I have personal knowledge of the
16 facts set forth in this Declaration and, if called as a witness, could and would testify competently
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2.
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The parties are submitting a Stipulation Regarding Deadline to Request Costs
19 and/or Fees in order to facilitate ongoing discussions between the parties and to potentially
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This Court has not granted any previous extensions of time for Juniper to file any
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4.
The requested extension of time will have no effect on the schedule for this case.
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I declare under penalty of perjury that the foregoing is true and correct.
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Executed this 22nd day of March, 2013, in Park City, Utah.
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/s/ David C. McPhie
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David C. McPhie
Case No. C 10-4234 SI
2793618
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