Playvision Labs, Inc. v. Roberts et al
Filing
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ORDER GRANTING 23 STIPULATION to Extend the Briefing Schedule and Continue the Hearing on Defendant Greg Roberts' Motion to Dismiss. Responses due by 7/19/2012. Replies due by 7/26/2012. Motion Hearing set for 8/10/2012 09:00 AM in Courtroom 11, 19th Floor, San Francisco before Hon. Jeffrey S. White.. Signed by Judge Jeffrey S. White on 6/27/12. (jjoS, COURT STAFF) (Filed on 6/27/2012)
Case3:12-cv-00171-JSW Document23 Filed06/27/12 Page1 of 3
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JAMES G. GATTO (pro hac vice to be submitted)
james.gatto@pillsburylaw.com
JENNA F. LEAVITT #213574
jenna.leavitt@pillsburylaw.com
PILLSBURY WINTHROP SHAW PITTMAN LLP
725 South Figueroa Street, Suite 2800
Los Angeles, CA 90017-5406
Telephone: (213) 488-7100
Facsimile: (213) 629-1033
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,
Plaintiff,
vs.
GREG ROBERTS, an individual; and
SUZANNE ROBERTS, an individual,
Defendants.
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Case No.: CV 12-0171 JSW
SECOND JOINT STIPULATION AND
[PROPOSED] ORDER TO EXTEND THE
BRIEFING SCHEDULE AND CONTINUE
THE HEARING ON DEFENDANT GREG
ROBERTS’ MOTION TO DISMISS
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 Second Joint Stipulation and [Proposed] Order to Extend the Briefing Schedule and
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Continue the Hearing on Defendant Greg Roberts’ Motion to Dismiss (the “Motion to Dismiss”),
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scheduled to be heard on July 20, 2012.
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respectfully request that the Court Order as follows:
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Accordingly, the parties hereby stipulate and
WHEREAS, PlayVision and Roberts are currently in negotiations to settle the present
dispute;
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CV 12-0171 JSW
JOINT STIPULATION AND
[PROPOSED] ORDER TO EXTEND
Case3:12-cv-00171-JSW Document23 Filed06/27/12 Page2 of 3
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WHEREAS, the parties participated through their counsel in a telephonic settlement
conference on June 21, 2012;
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WHEREAS, during the parties’ settlement conference, counsel for the parties met and
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conferred regarding the hearing date and briefing deadlines for the Motion to Dismiss, including
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PlayVision’s opposition and subsequently Roberts’ reply;
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WHEREAS, the parties stipulate, subject to the Court’s approval, that PlayVision’s time
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to file an opposition to the Motion to Dismiss shall be extended for three weeks from the current
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due date of June 28, 2012 to July 19, 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 for three weeks from
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the current due date of July 5, 2012 to July 26, 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;
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WHEREAS, the requested extension to the briefing schedule will cause the need for the
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Hearing on the Motion to Dismiss scheduled on July 20, 2012, to be extended into August,
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pursuant to the Court’s schedule;
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WHEREAS, the requested extension will not cause any delay to the remainder of the case
schedule;
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WHEREAS, this is the third request by the parties hereto to extend any deadlines in this
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case, the first being an informal extension to Roberts’ deadline for providing a response to the
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Complaint (from May 23, 2012 to May 30, 2012) and the second being the first request to extend
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the briefing schedule for the Motion to Dismiss which was granted by this Court on June 13,
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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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CV 12-0171 JSW
JOINT STIPULATION AND
[PROPOSED] ORDER TO EXTEND
Case3:12-cv-00171-JSW Document23 Filed06/27/12 Page3 of 3
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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 July 19, 2012, (2) Roberts’ time to file a reply in support of his Motion to Dismiss shall
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be extended to and including July 26, 2012, and (3) the hearing on the Motion to Dismiss shall be
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continued until August, pursuant to the Court’s schedule.
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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 27, 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 27, 2012.
Respectfully submitted,
MITCHELL + COMPANY
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By
/s/ Brian E. Mitchell
Brian E. Mitchell
Attorney for Defendant Greg Roberts
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
The Court shall hold a hearing on the motion to dismiss on Friday, August 10, 2012 at 9:00 a.m. If
the Court finds the matter suitable for disposition without oral argument, it shall notify the parties
in advance of the hearing.
Dated: June 27, 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
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