Bradford Technologies, Inc. v. NCV Software.com et al

Filing 39

STIPULATION AND ORDER re #36 Stipulation for Extension of Time to Reply, filed by Karma Technologies, LLC. Responses due by 11/30/2011.. Signed by Judge Elizabeth D Laporte on 11/22/2011. (kns, COURT STAFF) (Filed on 11/23/2011)

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GREENBERG TRAURIG, LLP
Kurt A. Kappes, CA Bar No. 146384
[e-mail]
Matthew L. Reagan, CA Bar No. 261832
[e-mail]
1201 K Street, Suite 1100
Sacramento, California 95814
Telephone: [phone]
Facsimile: [phone]
ANDERSON & KARRENBERG
Thomas R. Karrenberg (admitted pro hac vice)
[e-mail]
Heather M. Sneddon (admitted pro hac vice)
[e-mail]
Samantha J. Slark (admitted pro hac vice)
[e-mail]
50 West Broadway, Suite 700
Salt Lake City, Utah 84101
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
KARMA TECHNOLOGIES, LLC

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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BRADFORD TECHNOLOGIES, INC.,
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)
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Plaintiff,
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v.
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NCV SOFTWARE.com, an entity of unknown )
form; METRO NATIONAL FINANCIAL,
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LLC, a Utah limited liability company,
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KARMA TECHNOLOGIES, LLC, a Utah
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limited liability company, JOHN DAVID
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BIGGERS, an individual, RODNEY
)
NEWMAN, an individual, RICHARD PETER )
STEVES, an individual, RICHARD FRANK, )
an individual, and DOES 1-50,
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Defendants.
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)

Case No. 3:11-CV-04621 (EDL)
[PROPOSED] ORDER GRANTING
STIPULATED REQUEST FOR
EXTENSION OF TIME FOR KARMA
TECHNOLOGIES, LLC TO FILE A
REPLY IN SUPPORT OF ITS MOTION
TO DISMISS OR, IN THE
ALTERNATIVE, FOR MORE
DEFINITE STATEMENT
Date: December 13, 2011
Time: 2:00 p.m.
Dept./Place: Courtroom E – 15th Floor
Judge: Magistrate Judge Elizabeth D. Laporte

Defendant Karma Technologies, LLC (“Karma”), by and through its undersigned
counsel, hereby requests an extension of time to file a reply memorandum in support of its
Motion to Dismiss or, in the Alternative, for More Definite Statement (the “Motion to Dismiss”).
[PROPOSED] ORDER GRANTING STIPULATED REQUEST FOR
EXTENSION OF TIME FOR KARMA TECHNOLOGIES, LLC TO FILE
A REPLY IN SUPPORT OF ITS MOTION TO DISMISS OR, IN THE
ALTERNATIVE, FOR MORE DEFNIITE STATEMENT

Case No. 3:11-CV-04621-EDL
Page 1

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The reply is currently due on Wednesday, November 23, 2011 (the day before Thanksgiving),

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and Karma requests an extension until November 30, 2011.

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As set forth in the Declaration of Heather M. Sneddon, filed concurrently herewith,

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Karma requests the foregoing extension in light of the Thanksgiving holiday and the previously-

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scheduled family vacations of its attorneys. Karma has not previously requested an extension of

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time by stipulation or through Court order. In addition, because the hearing on Karma’s Motion

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to Dismiss is not scheduled until December 13, 2011, the filing of Karma’s reply memorandum

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by November 30, 2011 should not affect the schedule in this case. Finally, Plaintiff Bradford

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Technologies, LLC, through its undersigned counsel, stipulates to Karma’s requested extension.

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Accordingly, Karma respectfully requests that it be granted an extension until November
30, 2011 to file a reply memorandum in support of its Motion to Dismiss.

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Respectfully submitted,
DATED: November 22, 2011

GREENBERG TRAURIG, LLP

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By: /s/ Matthew L. Reagan

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- and -

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ANDERSON & KARRENBERG
Thomas R. Karrenberg
Heather M. Sneddon
Samantha J. Slark

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Attorneys for Defendant
KARMA TECHNOLOGIES, LLC

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Stipulated:

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DATED: November 22, 2011

THE HERITAGE LAW GROUP, P.C.

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By: /s/ Roger D. Wintle

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Attorneys for Plaintiff
BRADFORD TECHNOLOGIES, INC.

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[PROPOSED] ORDER GRANTING STIPULATED REQUEST FOR
EXTENSION OF TIME FOR KARMA TECHNOLOGIES, LLC TO FILE
A REPLY IN SUPPORT OF ITS MOTION TO DISMISS OR, IN THE
ALTERNATIVE, FOR MORE DEFNIITE STATEMENT

Case No. 3:11-CV-04621-EDL
Page 2

ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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DATED: November ______, 2011
BY THE COURT:

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The Honorable Elizabeth D. Laporte

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U.S. District Court Magistrate Judge

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[PROPOSED] ORDER GRANTING STIPULATED REQUEST FOR
EXTENSION OF TIME FOR KARMA TECHNOLOGIES, LLC TO FILE
A REPLY IN SUPPORT OF ITS MOTION TO DISMISS OR, IN THE
ALTERNATIVE, FOR MORE DEFNIITE STATEMENT

Case No. 3:11-CV-04621-EDL
Page 3