Mycone Dental Supply Co., Inc. v. Creative Nail Design, Inc.
Filing
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STIPULATION AND ORDER RE 109 EXTENDING TIME FOR DEFENDANT CREATIVE NAIL DESIGN, INC. TO FILE ITS REPLY CLAIM CONSTRUCTION BRIEF PURSUANT TO PATENT LOCAL RULE 4-5. Signed by Judge Richard Seeborg on 2/11/13. (cl, COURT STAFF) (Filed on 2/11/2013)
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VENABLE LLP
ADAM R. HESS (pro hac vice)
Email: arhess@venable.com
CHRISTOPHER T. LA TESTA (pro hac vice)
Email: ctlatesta@venable.com
575 7th Street N.W.
Washington, D.C. 20004
Telephone: (202) 344-4547
Facsimile: (202) 344-8300
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FREITAS TSENG & KAUFMAN LLP
CRAIG KAUFMAN (SBN 159458)
Email: ckaufman@ftklaw.com
100 Marine Parkway
Suite 200
Redwood Shores, CA 94065
Telephone: (650) 730-5557
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Attorneys for Defendant
CREATIVE NAIL DESIGN, INC.
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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MYCONE DENTAL SUPPLY CO., INC.,
D/B/A/ KEYSTONE RESEARCH &
PHARMACEUTICAL,
Plaintiff,
vs.
CREATIVE NAIL DESIGN, INC.,
Defendant.
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Case No. 3:12-cv-00747-RS
JOINT STIPULATION AND
[PROPOSED] ORDER EXTENDING
TIME FOR DEFENDANT CREATIVE NAIL
DESIGN, INC. TO FILE ITS REPLY CLAIM
CONSTRUCTION BRIEF PURSUANT TO
PATENT LOCAL RULE 4-5
AND RELATED COUNTERCLAIM
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Pursuant to Local Rule 6-1, Defendant/Counterclaim Plaintiff Creative Nail Design, Inc.
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(“CND”), seeks to extend the deadline for CND to file its reply claim construction brief
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pursuant to Patent Local Rule 4-5 from February 15, 2013 to February 19, 2013 for the resons
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JOINT STIPULATION EXTENDING TIME FOR DEFENDANT
CND TO FILE ITS REPLY CLAIM CONSTRUCTION BRIEF
CASE NO. 3:12-CV-00747 RS
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stated below.
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Defendants Young Nails, Inc., Cacee, Inc. and Nail Systems International (“Counterclaim
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Plaintiff Mycone Dental Supply Co., Inc. (“Keystone”), and Counterclaim
Defendants”), do not oppose CND’s proposed extension. Therefore, the parties, by and through
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their respective counsel, hereby stipulate, subject to the Court’s approval, to extend the deadline
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for CND to file its reply claim construction brief pursuant to Patent Local Rule 4-5 from
February 15, 2013 to February 19, 2013.
This extension will not affect the date of the claim construction hearing or any other
deadlines set by the Court.
On February 8, 2013, Keystone and the Counterclaim Defendants filed their Responsive
Claim Construction Brief. Pursuant to the Case Management Scheduling Order, as modified by
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Court Order on January 7, 2013 (see Dkt. 95), the deadline for CND to file its Reply Claim
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Construction Brief is February 15, 2013. CND has requested additional time, with the approval
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of Keystone and Counterclaim Defendants, beyond the deadline to do so because CND’s lead
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counsel of record is recovering from recent surgery.
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Dated: February 11, 2013
Respectfully submitted,
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FREITAS TSENG & KAUFMAN LLP
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By /s/ Craig Kaufman
CRAIG KAUFMAN (SBN 159458)
100 Marine Parkway, Suite 200
Redwood Shores, CA 94065
Telephone: (650) 730-5557
Email: ckaufman@ftklaw.com
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Attorneys for Defendant
CREATIVE NAIL DESIGN, INC.
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FISH & RICHARDSON P.C.
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By /s/ John R. Lane
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JOINT STIPULATION EXTENDING TIME FOR DEFENDANT
CND TO FILE ITS REPLY CLAIM CONSTRUCTION BRIEF
CASE NO. 3:12-CV-00747 RS
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JOHN M. FARRELL (SBN 99649)
500 Arguello Street, Suite 500
Redwood City, CA 94063
Telephone: (650) 839-5070
Facsimile: (650) 839-5071
Email: farrell@fr.com
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John R. Lane (admitted pro hac vice)
1 Houston Center
1221 McKinney Street
Suite 2800
Houston, TX 77010
Telephone: (713) 654-5307
Email: jlane@fr.com
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Attorneys for Plaintiff
MYCONE DENTAL SUPPLY CO., INC., D/B/A/
KEYSTONE RESEARCH & PHARMACEUTICAL
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ATTESTATION OF CONCURRENCE
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I, Craig R. Kaufman, am the ECF User whose ID and password are being used to file this
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Joint Stipulation and [Proposed] Order Extending Time for Defendant Creative Nail Design, Inc.
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to File Its Reply Claim Construction Brief Pursuant to Patent Local Rule 4.-5. I attest that,
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pursuant to United States District Court, Northern District of California Civil L.R. 5-1(i)(3) and
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General Order 45, concurrence in the filing of this document has been obtained from Counsel for
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Plaintiff Mycone Dental Supply Co., Inc., d/b/a/ Keystone Research & Pharmaceutical. I declare
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under penalty of perjury that the foregoing is true and correct.
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Date: February 11 2013
/s/ Craig R. Kaufman
Craig R. Kaufman
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JOINT STIPULATION EXTENDING TIME FOR DEFENDANT
CND TO FILE ITS REPLY CLAIM CONSTRUCTION BRIEF
CASE NO. 3:12-CV-00747 RS
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[PROPOSED] ORDER
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PURSUANT TO THE FOREGOING STIPULATION, IT IS HEREBY ORDERED
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THAT the deadline for Defendant Creative Nail Design, Inc. to file its Reply Claim Construction
Brief pursuant to Patent Local Rule 4-5 is extended from February 15, 2013 to February 19, 2013.
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IT IS SO ORDERED.
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Dated: February ___, 2013
___________________________________
Hon. Richard Seeborg
United States District Judge
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JOINT STIPULATION EXTENDING TIME FOR DEFENDANT
CND TO FILE ITS REPLY CLAIM CONSTRUCTION BRIEF
CASE NO. 3:12-CV-00747 RS
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