Adobe Systems Incorporated v. Ghermazian et al

Filing 15

ORDER GRANTING 12 Joint MOTION to Continue Case Management Conference. Case Management Statement due by 3/9/2012. Case Management Conference set for 3/16/2012 01:30 PM in Courtroom 11, 19th Floor, San Francisco. Signed by Judge Jeffrey S. White on November 28, 2011. (jswlc3, COURT STAFF) (Filed on 11/28/2011)

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Case3:11-cv-03882-JSW Document12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Filed11/10/11 Page1 of 4 J. Andrew Coombs (SBN 123881) andy@coombspc.com Nicole L. Drey (SBN 250235) nicole@coombspc.com J. Andrew Coombs, A P. C. 517 East Wilson Avenue, Suite 202 Glendale, California 91206 Telephone: (818) 500-3200 Facsimile: (818) 300-3201 Attorneys for Plaintiff Adobe Systems Incorporated John D. McCurdy (SBN 54091) jmccurdy@jmll.com Reagan E. Boyce (SBN 248064) reagan.boyce@jmll.com McCurdy & Leibl, LLP 12925 Riverside Drive, Third Floor Sherman Oaks, California 91423 Telephone: (818) 380-0123 Facsimile: (818) 380-0124 Attorneys for Defendants Maryam Ghermazian, an individual and d/b/a www.saveintheusa.com, and Technology One Online d/b/a Tech 1, Technology 1 and Technology One Corporation 16 17 UNITED STATES DISTRICT COURT 18 NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO) 19 20 21 22 23 Adobe Systems Incorporated, Plaintiff, v. Maryam Ghermazian, et al. Defendants. 24 25 ALL RELATED CLAIMS 26 27 28 ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. CV11-3882 JSW STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND [PROPOSED] ORDER AS MODIFIED HEREIN Date: December 2, 2011 Time: 1:30 p.m. Court: Hon. Jeffrey S. White PLAINTIFF Adobe Systems Incorporated (“Adobe”), by and through its counsel of record, and Defendants Maryam Ghermazian, an individual and d/b/a www.saveintheusa.com, and Adobe v. Ghermazian, et al.: Stipulation to Continue CMC -1- Case3:11-cv-03882-JSW Document12 1 2 Filed11/10/11 Page2 of 4 Technology One Online d/b/a Tech 1, Technology 1 and Technology One Corporation (collectively “Defendants”), by and through their counsel of record, hereby stipulate and request as 3 follows: 4 WHEREAS Adobe filed its complaint on or about August 8, 2011; 5 WHEREAS counsel for Defendants first contacted counsel for Adobe on or about 6 7 November 10, 2011, regarding her recent retention by Defendants; 8 9 WHEREAS counsel for Defendants has indicated that she will accept service for Defendants; 10 WHEREAS an Acknowledgment of Service is being sent to counsel for Defendants on or 11 about November 10, 2011; 12 WHEREAS counsel for Defendants has not yet reviewed the Complaint and will need 13 14 sufficient time to prepare a response; WHEREAS the return of the Acknowledgment will give Defendants until January 9, 2012, 15 16 to respond to the Complaint; 17 18 WHEREAS Defendant Morris Cohen a/k/a Morris Kohanian, an individual and d/b/a www.saveintheusa.com (“Cohen”), remains unserved; 19 WHEREAS Adobe has until December 6, 2011, to serve Defendant Cohen; 20 WHEREAS briefly continuing the Case Management Conference and all corresponding 21 22 deadlines will provide the Parties with additional time to possibly resolve this matter informally or, 23 alternatively, better brief the Court regarding the Parties’ positions and any outstanding issues; and 24 25 WHEREAS Defendants by agreeing to a continuation of the case management conference do not intend to waive, and expressly reserve any and all rights or defenses, including those based 26 on subject matter jurisdiction, personal jurisdiction or venue. 27 28 /// Adobe v. Ghermazian, et al.: Stipulation to Continue CMC -2- Case3:11-cv-03882-JSW Document12 Filed11/10/11 Page3 of 4 March 16, 2012 at 1:30 p.m. A joint case management statement is due on March 9, 2012. If Plaintiff requires additional time to serve Defendant Cohen, they should file the appropriate request with the Court. November 28,

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