Hartford Casualty Insurance Company et al v. Pandora Media, Inc.

Filing 19

STIPULATION AND ORDER RE 18 REQUESTING EXTENSION OF TIME TO RESPOND TO THE COMPLAINT. Signed by Judge Richard Seeborg on 4/19/12. (cl, COURT STAFF) (Filed on 4/19/2012)

Case3:11-cv-06701-RS Document18 Filed04/19/12 Page1 of 3

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Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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SARA M. THORPE (SBN: 146529)
GEOFFREY HUTCHINSON (SBN: 212050)
GORDON & REES LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
JENNY L. SAUTTER (SBN: 192317)
MEAGHER & GEER, P.L.L.P.
33 South Sixth Street, Suite 4400
Minneapolis, MN 55402
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Plaintiffs
HARTFORD CASUALTY INSURANCE COMPANY and
HARTFORD INSURANCE COMPANY OF THE MIDWEST

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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HARTFORD CASUALTY INSURANCE
COMPANY and HARTFORD INSURANCE
COMPANY OF THE MIDWEST,

)
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Plaintiffs,
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vs.
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PANDORA MEDIA, INC., a Delaware Corp. et al. )
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Defendants.
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Case No. 4:11-cv-06701-RS
JOINT STIPULATION
REQUESTING EXTENSION OF
TIME TO RESPOND TO THE
COMPLAINT; [PROPOSED]
ORDER
Filed: December 29, 2011

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Plaintiffs HARTFORD CASUALTY INSURANCE COMPANY and HARTFORD

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INSURANCE COMPANY OF THE MIDWEST (collectively “Hartford”) and defendant

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PANDORA MEDIA, INC. (“Pandora”) request an Order extending additional time – to May 21,

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2012 - to Pandora in which to respond to the Complaint in this matter, pursuant to Local Rule 6-

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1(b). Pursuant to Local Rule 6-2, the parties also request the Court continue the Case

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Management Conference, currently scheduled for May 17, 2012, for an additional 35 days, to

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JOINT STIPULATION REQUESTING EXTENSION OF TIME TO RESPOND TO THE COMPLAINT;
[PROPOSED] ORDER

Case3:11-cv-06701-RS Document18 Filed04/19/12 Page2 of 3

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June 21, 2012. The requested time modifications will permit the parties to continue their

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discussions regarding resolution of their dispute, which could render litigation unnecessary.

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The instant lawsuit was filed on December 29, 2011. On December 29, 2011, the Court

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issued an Order Setting Initial Case Management Conference and ADR Deadlines, which

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included an Initial Case Management Conference on April 11, 2012.

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The Summons and Complaint were served on Pandora’s agent on February 22, 2012,

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making Pandora’s response due on March 14, 2012. Hartford agreed that Pandora could have

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until March 21, 2012 to respond to the Complaint, pursuant to Local Rule 6-1(a).

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On March 20, 2012, the parties filed a Joint Stipulation Requesting Extension of Time To
Respond To The Complaint, requesting an extension of the due date to April 20, 2012. On

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Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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March 22, 2012, the Court entered an Order extending Pandora’s responsive due date to April

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20, 2012, and vacating the Initial Case Management Conference and ADR Deadlines previously

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set by Order dated December 29, 2012. On March 22, 2012, the Court also ordered the parties to

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attend a Case Management Conference on May 17, 2012 at 10:00 a.m.

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To permit the parties to work towards resolution of the case, the parties request the Court

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extend the date on which Pandora is to respond to the Complaint to May 21, 2012. The parties

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further request that the Court continue the Case Management Conference to June 21, 2012.

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If the instant request is granted, the Case Management Conference, and associated dates,

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would be continued for 35 days. The parties Rule 26(f) conference would take place on or

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before May 31, 2012. The Joint Case Management Statement including Discovery Plan would

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be due June 14, 2012.

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SO STIPULATED.

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Dated: April 19, 2012

GORDON & REES LLP

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By_____/s/ Sara M. Thorpe _______
Sara M. Thorpe
Geoffrey Hutchinson
Attorneys for HARTFORD CASUALTY
INSURANCE COMPANY and HARTFORD
INSURANCE COMPANY OF THE MIDWEST

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JOINT STIPULATION REQUESTING EXTENSION OF TIME TO RESPOND TO THE COMPLAINT;
[PROPOSED] ORDER

Case3:11-cv-06701-RS Document18 Filed04/19/12 Page3 of 3

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Dated: April 19, 2012

COVINGTON & BURLING LLP

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By_______/s/ Donald W. Brown________
Donald W. Brown
Attorney for PANDORA MEDIA, INC.

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ORDER

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The Parties having stipulated and agreed to a further extension of time in which Pandora
is to respond to the Hartford’s Complaint in order to pursue settlement discussions, and good
cause appearing,

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Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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PURSUANT TO STIPULATION, IT IS SO ORDERED,

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Defendant, PANDORA MEDIA, INC. shall file a response to the complaint on or before
May 21, 2012.
The Case Management Conference currently scheduled for May 17, 2012 is continued to

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June 21, 2012 at 10:00 a.m. in Courtroom 3 on the 17th Floor of the United States Courthouse,

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450 Golden Gate Avenue, San Francisco. A further Order setting forth a new date for the Initial

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Case Management Conference, and accompanying deadlines will issue separately.

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Dated: April __, 2012

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By__________________ ____________
Hon. Richard Seeborg

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HCIC/1075168/12328145v.1

JOINT STIPULATION REQUESTING EXTENSION OF TIME TO RESPOND TO THE COMPLAINT;
[PROPOSED] ORDER