Xoom Corporation v. Motorola Trademark Holdings, LLC et al

Filing 18

STIPULATION re 17 Order --- CONSENTED MOTION FOR AN EXTENSION OF CASE MANAGEMENT CONFERENCE AND RELATED DEADLINES --- by Xoom Corporation. (Attachments: # 1 Proposed Order, # 2 Certificate/Proof of Service)(Alpert, Rochelle) (Filed on 7/14/2011)

1
2
3
4
5
6

ROCHELLE D. ALPERT, State Bar No. 065037
LEIGHA E. WEINBERG, State Bar No. 251795
MORGAN, LEWIS & BOCKIUS LLP
One Market, Spear Street Tower
San Francisco, CA 94105-1126
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
[e-mail]
Attorneys for Plaintiff
XOOM CORPORATION

7
8

UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA

10
11

XOOM CORPORATION, a California
Corporation,
Plaintiff,

12
vs.

13
14
15
16
17

Case No. 11-CV-00848 (CRB)
CONSENTED MOTION FOR AN
EXTENSION OF CASE MANAGEMENT
CONFERENCE AND RELATED
DEADLINES

MOTOROLA TRADEMARK
DATE:
HOLDINGS, LLC, a Delaware limited
TIME:
liability company, MOTOROLA
COURTROOM:
MOBILITY, INC., a Delaware corporation,
and MOTOROLA MOBILITY
HOLDINGS, INC., a Delaware
corporation, and DOES 1 through 10
inclusive

18

July 22, 2011
8:30 a.m.
6, 17TH FLOOR

Defendants.

19
20

Plaintiff Xoom Corporation (“Xoom”) filed the complaint in this action on February 23,

21

2011. Pursuant to Rule 4(m) of the Federal Rules of Civil Procedure, Xoom had 120 days, or

22

until June 23, 2011, to serve the summons and complaint. On June 22, 2011 the parties filed a

23

Consented Motion for an Extension of Service Deadline requesting that the service deadline be

24

extended to July 13, 2011. The motion was granted by the Court on June 24, 2011 and the Case

25

Management Conference was moved to July 22. The parties subsequently filed a Second

26

Consented Motion for an Extension of Service Deadline requesting that the service deadline be

27

extended to August 3, 2011 because of settlement negotiations. The motion was granted on

28

June 12, 2011.

M ORGAN , L EWIS &
B OCKIUS LLP
ATTORNEYS AT LAW

CASE NO.: 11-CV-00848 (CRB)
CONSENTED MOTION FOR EXTENSION OF CASE MANAGEMENT
CONFERENCE AND RELATED DATES

SAN FRANCISCO

DB2/22554898.1

1

The Case Management Conference in this proceeding is set to occur on July 22, 2011.

2

Although Defendants have not yet been served, various deadlines are triggered by the date for the

3

Case Management Conference, including a July 15, 2011 deadline for filing a joint case

4

management statement.

5

Given that Xoom has not yet served the Complaint and is in settlement discussions with

6

Defendants about this matter, there is good cause for the Court to continue the Case Management

7

Conference and to extend the various dates calculated from the Case Management Conference

8

date. Accordingly, Xoom respectfully requests a continuance of the Case Management

9

Conference until August 12, 2011.

10
11

Dated: July 14, 2011

MORGAN, LEWIS & BOCKIUS LLP
ROCHELLE D. ALPERT
LEIGHA E. WILBUR

12
13

By /s/Rochelle D. Alpert
Rochelle D. Alpert

14
15

Attorneys for Plaintiff
XOOM CORPORATION

16
17
18
19
20
21
22
23
24
25
26
27
28

M ORGAN , L EWIS &
B OCKIUS LLP
ATTORNEYS AT LAW

2

SAN FRANCISCO

DB2/22554898.1

CASE NO.: 11-CV-00848 (CRB)
CONSENTED MOTION FOR EXTENSION OF CASE MANAGEMENT
CONFERENCE AND RELATED DATES