Playvision Labs, Inc. v. Roberts et al

Filing 22

ORDER GRANTING AS MODIFIED 21 STIPULATION to Extend The Briefing Schedule on Defendant Greg Roberts' Motion to Dismiss. Responses due by 6/28/2012. Replies due by 7/5/2012. Motion Hearing set for 7/20/2012 09:00 AM in Courtroom 11, 19th Floor, San Francisco before Hon. Jeffrey S. White.. Signed by Judge JEFFREY S. WHITE on 6/13/12. (jjoS, COURT STAFF) (Filed on 6/13/2012)

Case3:12-cv-00171-JSW Document21 Filed06/13/12 Page1 of 3

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JAMES G. GATTO (pro hac vice to be submitted)
[e-mail]
JENNA F. LEAVITT #213574
[e-mail]
PILLSBURY WINTHROP SHAW PITTMAN LLP
725 South Figueroa Street, Suite 2800
Los Angeles, CA 90017-5406
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
PLAYVISION LABS, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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PLAYVISION LABS, INC., a California
corporation,

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Plaintiff,
vs.
GREG ROBERTS, an individual; and
SUZANNE ROBERTS, an individual,
Defendants.

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Case No.: CV 12-0171 JSW
JOINT STIPULATION AND [PROPOSED]
ORDER TO EXTEND THE BRIEFING
SCHEDULE ON DEFENDANT GREG
ROBERTS’ MOTION TO DISMISS
AS MODIFIED
Civil L.R. 6-2
Judge: Hon. Jeffrey S. White

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Pursuant to Civil L.R. 6-1(b), 6-2, and 7-12, Plaintiff PlayVision Labs, Inc.

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(“PlayVision”) and Defendant Greg Roberts (“Roberts”), by and through their counsel, hereby

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submit this Joint Stipulation and [Proposed] Order to Extend the Briefing Schedule on Defendant

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Greg Roberts’ Motion to Dismiss (the “Motion to Dismiss”), scheduled to be heard on July 13,

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2012. Accordingly, the parties hereby stipulate and respectfully request that the Court Order as

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follows:

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WHEREAS, PlayVision and Roberts are currently in negotiations to settle the present
dispute and have scheduled a telephonic settlement conference to take place on June 21, 2012;

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CV 12-0171 JSW
JOINT STIPULATION AND
[PROPOSED] ORDER TO EXTEND

Case3:12-cv-00171-JSW Document21 Filed06/13/12 Page2 of 3

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WHEREAS, counsel for the parties met and conferred by telephone on June 12, 2012

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regarding the deadlines for PlayVision’s opposition to the Motion to Dismiss and subsequently

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Roberts’ reply;

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WHEREAS, the parties stipulate, subject to the Court’s approval, that PlayVision’s time
to file an opposition to the Motion to Dismiss shall be extended to and including June 28, 2012;

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WHEREAS, the parties further stipulate, subject to the Court’s approval, that Roberts’

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time to file a reply in support of his Motion to Dismiss shall be extended to and including July 5,

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2012;

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WHEREAS, the parties in good faith believe that this extension will assist in their ability
to settle the matter between them without the need for further court intervention;
WHEREAS, the requested extension to the briefing schedule will have no effect on the
Hearing on the Motion to Dismiss scheduled on July 13, 2012, or on the case schedule;

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WHEREAS, this is the second request by the parties hereto to extend any deadlines in

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this case, the first being an informal extension to Roberts’ deadline for providing a response to

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the Complaint (from May 23, 2012 to May 30, 2012);

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WHEREAS, there has also been one prior extension with the other Defendant, Suzanne

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Roberts, in which this Court granted the requested sixty (60) day stay with respect to the action

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against Ms. Roberts;

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WHEREAS, pursuant to Civil L.R. 6-2, the Declaration of Jenna F. Leavitt, counsel for
PlayVision, in support of the request is being filed contemporaneously herewith;

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NOW, THEREFORE, the parties hereby stipulate, subject to the Court’s approval, that:

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(1) PlayVision’s time to file an opposition to the Motion to Dismiss shall be extended to and

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including June 28, 2012, and (2) Roberts’ time to file a reply in support of his Motion to Dismiss

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shall be extended to and including July 5, 2012.

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CV 12-0171 JSW
JOINT STIPULATION AND
[PROPOSED] ORDER TO EXTEND

Case3:12-cv-00171-JSW Document21 Filed06/13/12 Page3 of 3

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I, Jenna F. Leavitt, as the e-filing signatory, attest that concurrence in filing this document

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has been obtained from Brian E. Mitchell.

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Dated: June 13, 2012.
Respectfully submitted,

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PILLSBURY WINTHROP SHAW PITTMAN LLP

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By

/s/ Jenna F. Leavitt
Jenna F. Leavitt
Attorneys for Plaintiff PLAYVISION LABS, INC.

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Dated: June 13, 2012.
Respectfully submitted,

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MITCHELL + COMPANY

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By

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/s/ Brian E. Mitchell
Brian E. Mitchell
Attorney for Defendant Greg Roberts

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
Because the deadline to submit the reply brief is less than fourteen days before the hearing, the Court
continues the hearing to July 20, 2012 at 9:00 a.m.

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Dated: June 13, 2012

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Honorable Jeffrey S. White
United States District Court Judge

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CV 12-0171 JSW
JOINT STIPULATION AND
[PROPOSED] ORDER TO EXTEND