Adobe Systems Incorporated v. Dracup et al

Filing 14

STIPULATION AND ORDER Case Management Conference set for 2/24/2012 10:00 AM in Courtroom 1, 17th Floor, San Francisco before Hon. Samuel Conti.. Signed by Judge Samuel Conti on 11/3/11. (tdm, COURT STAFF) (Filed on 11/3/2011)

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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
Adobe Systems Incorporated
George A. Shohet (SBN 112697)
[e-mail]
Law Offices of George A. Shohet
245 Main Street, Suite 310
Venice, California 90291
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Defendants
Jonathan Dracup, an individual and d/b/a
www.buycheapsoftware.com, Buy Cheap
Software, Inc., and Softman Products, LLC
a/k/a Softman Products Company, LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO)

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Adobe Systems Incorporated,
Plaintiff,
v.
Jonathan Dracup, et al.,
Defendants.

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Case No. CV11-3880 SC
STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE AND
[PROPOSED] ORDER
Date: November 18, 2011
Time: 10:00 a.m.
Court: Hon. Samuel Conti

PLAINTIFF Adobe Systems Incorporated (“Plaintiff”) and Defendants Jonathan Dracup, an

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individual and d/b/a www.buycheapsoftware.com; Buy Cheap Software, Inc.; and Softman

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Products, LLC a/k/a Softman Products Company, LLC (collectively “Defendants”), by and through

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their respective counsel of record, hereby stipulate and agree as follows:

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Adobe v. Dracup, et al.: Stip to Continue CMC

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WHEREAS Plaintiff filed its complaint on or about August 8, 2011;

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WHEREAS Plaintiff is to serve Defendants on or before December 6, 2011;

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WHEREAS Defendants’ counsel has agreed to accept service for Defendants;
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WHEREAS Plaintiff mailed a waiver of service to Defendants on or about October 25,

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2011;
WHEREAS Defendants have not yet returned the waiver of service and have until

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November 24, 2011, to do so;

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WHEREAS, upon return of the waiver of service within the prescribed timeframe,
Defendants shall have until December 24, 2011, to respond to the Complaint;

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WHEREAS Defendants have not yet filed a response to the Complaint;
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WHEREAS the Parties are attempting to resolve the claims alleged in the Complaint

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without further intervention of the Court;
WHEREAS continuing the Case Management Conference until after Defendants have been

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served and have had a chance to respond to the Complaint would be the most efficient use of the

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Court’s time and resources;

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WHEREAS continuing the Case Management Conference and all corresponding deadlines

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will provide the Parties with additional time to engage in discussions to resolve this matter; and
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Adobe v. Dracup, et al.: Stip to Continue CMC

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February 24, 2012 @ 10:00 a.m.

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PROOF OF SERVICE
I, the undersigned, certify and declare that I am over the age of 18 years, employed in the
County of Los Angeles, and not a party to the above-entitled cause. I am employed by a member
of the Bar of the United States District Court of California. My business address is 517 East
Wilson Avenue, Suite 202, Glendale, California 91206.
On November 2, 2011, I served the:
STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE
AND [PROPOSED] ORDER
for the following civil action:
Adobe Systems Incorporated v. Dracup, et al.

on the following interested parties in this action:
George A. Shohet
Law Offices of George A. Shohet
245 Main Street, Suite 310
Venice, CA 90291
by placing a true and correct copy thereof in an envelope to be immediately sealed thereafter. I
am readily familiar with the office’s practice of collecting and processing correspondence for
mailing. Under that practice it would be deposited with the United States Postal Service on the
same day with postage thereon fully prepaid at Glendale, California, in the ordinary course of
business. I am aware that on motion of the party served, service may be presumed invalid if the
postal cancellation date or postage meter is more than one day after the date of deposit for
mailing in affidavit.
Place of Mailing: Glendale, California.
Executed on November 2, 2011, at Glendale, California.

_______/s Nicole L. Drey_______
Nicole L. Drey