Globalnavsource, Inc. et al v. Foreflight LLC

Filing 18

ORDER VACATING MOTION TO DISMISS HEARING. Signed by Judge Maria-Elena James on 8/4/2011. (cdnS, COURT STAFF) (Filed on 8/4/2011)

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GRELLAS SHAH LLP
GEORGE GRELLAS, ESQ. (SBN 83540)
([e-mail])
DHAIVAT H. SHAH, ESQ. (SBN 196382)
([e-mail])
20400 Stevens Creek Blvd, Suite 280
Cupertino, CA 95014
Telephone: (408) 255 - 6310
Facsimile: (408) 255 - 6350
Attorneys for Plaintiffs
GLOBALNAVSOURCE, INC. and
TRAILBEHIND, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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GLOBALNAVSOURCE, INC., a Florida
corporation, and TRAILBEHIND, INC., a
California corporation,

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Plaintiffs,
v.
FOREFLIGHT LLC, a Nevada limited
liability company. and DOES 1-50,
inclusive,

Case No.: CV11-02918 MEJ
JOINT STIPULATION AND PROPOSED
ORDER TO CONTINUE THE
DISCOVERY, BRIEFING, AND HEARING
SCHEDULE FOR DEFENDANT
FOREFLIGHT LLC’S MOTION TO
DISMISS

Defendants

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Stipulation And Proposed Order To Continue Discovery, Briefing, And Hearing Schedule For Defendant’s
Motion To Dismiss – Case No. CV11-02918 MEJ

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In light of the parties’ good faith efforts and progress towards settlement of the above-

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captioned matter, and pursuant to Civil L.R. 6-12, 7-7(a) and 7-2, and supported by the

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attached Declaration of David I. Siegel, Plaintiffs GlobalNavSource, Inc. and TrailBehind, Inc.

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(jointly, the “Plaintiffs”) and Defendant ForeFlight LLC (“Defendant”) respectfully submit

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this Joint Stipulation and Proposed Order to Continue Discovery, Briefing, And Hearing

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Schedule For Defendant’s Motion To Dismiss, and request the Court approve the stipulated

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agreement between the parties, as follows (the “Stipulated Order”):

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(1) Plaintiffs shall propound and serve limited jurisdictional discovery to Defendant

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(the “Jurisdictional Discovery”) no later than September 16, 2011;

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(2) Defendant shall respond to the Jurisdictional Discovery on or before October 17,

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2011; Defendant does not waive the right to object to any individual Jurisdictional

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Discovery requests or to require that any production of confidential information

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will take place pursuant to a mutually acceptable protective order;

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(3) Plaintiffs’ opposition to Defendant’s Motion to Dismiss pursuant to Fed. R. Civ. P.

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12(b)(2) (the “Motion to Dismiss”) shall be filed on or before November 4, 2011;

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(4) Defendant’s reply in further support of its Motion to Dismiss shall be filed on or

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before November 16, 2011;

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(5) Plaintiffs and Defendant will request a mutually agreeable hearing date for the

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Motion to Dismiss, to be set for on or after December 1, 2011.

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Respectfully submitted,

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GRELLAS SHAH LLP

PATTERSON SHERIDAN LLP
By: _____/s/__________________
Keith Jaasma, Esq.
Attorneys for Defendant
FOREFLIGHT LLP

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By: _______/s/______________
Dhaivat H. Shah, Esq.
Attorneys for Plaintiffs
GLOBALNAVSOURCE, INC. and
TRAILBEHIND, INC.
//

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//

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//

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//

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Stipulation And Proposed Order To Continue Discovery, Briefing, And Hearing Schedule For Defendant’s
Motion To Dismiss – Case No. CV11-02918 MEJ

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CERTIFICATION OF CONCURRENCE

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I, Dhaivat H. Shah, attest that Keith Jaasma has concurred in the filing of this document.

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________/s/_________________
Dhaivat H. Shah

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
By: _________________________
Hon. Maria-Elena James
United States Magistrate Judge
August 4, 2011
Date: ________________________

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Stipulation And Proposed Order To Continue Discovery, Briefing, And Hearing Schedule For Defendant’s
Motion To Dismiss – Case No. CV11-02918 MEJ