EON Corp IP Holdings LLC v. Sensus USA Inc et al

Filing 985

STIPULATION AND ORDER RE FOURTH JOINT STIPULATION TO EXTEND DEADLINES RE EON CORP. IP HOLDINGS, LLC.S 876 MOTION to Compel Defendant Motorola Solutions, Inc. to Produce Documents and Things. Responses due by 4/11/2014. Replies due by 4/18/2014. Signed by Judge Elizabeth D Laporte on 3/10/2014. (knm, COURT STAFF) (Filed on 3/10/2014)

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KILPATRICK TOWNSEND & STOCKTON LLP
FREDERICK L. WHITMER (admitted pro hac vice)
The Grace Building
1114 Avenue of the Americas
New York, NY 10026-7703
Telephone: [phone]
Facsimile [phone]
[e-mail]

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KILPATRICK TOWNSEND & STOCKTON LLP
CARL E. SANDERS (admitted pro hac vice)
JAMES L. HOWARD (admitted pro hac vice)
1001 West Fourth Street
Winston-Salem, NC 27101-2400
Telephone: [phone]; Facsimile: 336 607 7500
E-mail: [e-mail]
E-mail: [e-mail]
KILPATRICK TOWNSEND & STOCKTON LLP
STEVEN D. MOORE (State Bar No. 290875)
BYRON R. CHIN (State Bar No. 259846)
JESSICA L. HANNAH (State Bar No. 261802)
Two Embarcadero Center, 8th Floor
San Francisco, CA 94111
Telephone: [phone]; Facsimile: 415-576-0300
E-mail: [e-mail]
E-mail: [e-mail]
E-mail: [e-mail]
Attorneys for Defendant
MOTOROLA SOLUTIONS, INC.
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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EON CORP. IP HOLDINGS, LLC,
Plaintiff,

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v.
SENSUS USA INC.; et al,
.
Defendants.

Case No. C12-01011 JST (EDL)
FOURTH JOINT STIPULATION TO
EXTEND DEADLINES RE EON CORP.
IP HOLDINGS, LLC’S MOTION TO
COMPEL MOTOROLA SOLUTIONS,
INC. TO PRODUCE DOCUMENTS AND
THINGS
AND ORDER

AND RELATED COUNTERCLAIMS

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FOURTH JOINT STIPULATION TO EXTEND DEADLINES RE EON CORP. IP HOLDINGS, LLC’S
MOTION TO COMPEL MOTOROLA SOLUTIONS, INC. TO PRODUCE DOCUMENTS AND THINGS
CASE NO. C12-01011 JST (EDL)

Plaintiff EON Corp. IP Holdings LLC (“EON”) and Defendant Motorola Solutions Inc.

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(“MSI”) hereby stipulate and agree as follows:
WHEREAS EON filed a Motion to Compel MSI to Produce Documents and Things (Dkt.

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No. 876) on November 26, 2013,
WHEREAS EON and MSI previously stipulated to extend the deadlines relating to EON’s

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Motion to Compel pending finalization of settlement terms,
WHEREAS the Court granted EON and MSI’s prior Stipulated Requests on December 10,

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2013 (Dkt. No. 890), January 14, 2014 (Dkt. 910), and February 11, 2014 (Dkt. 936),
WHEREAS MSI’s Opposition to EON’s Motion to Compel is currently due on March 11,

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2014,
WHEREAS EON’s Reply in further support of its Motion to Compel is currently due on
March 18, 2014,
WHEREAS the hearing for the Motion to Compel is currently scheduled for May 6, 2014
at 2:00 p.m.,
WHEREAS EON and MSI reached a tentative settlement in principle during a conference
with Magistrate Judge Spero,
WHEREAS EON and MSI are continuing to finalize settlement terms, and continue to

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agree in the interest of judicial economy and the preservation of time to extend the deadlines

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relating to EON’s Motion to Compel pending finalization of settlement terms, after which this

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action will be dismissed as to MSI,

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WHEREAS the Court has previously granted in part four Motions to Shorten Time relating

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to other Motions to Compel (Dkt. Nos. 802, 807, 814, 869), and granted three Stipulated Requests

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for an Extension of Time for Close of Fact Discovery and Expert Reports (Dkt. Nos. 872, 890,

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910, 966),

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NOW, THEREFORE, the parties, by and through their respective counsel of record, hereby

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stipulate and respectfully request that the Court issue an order under Civil L.R. 6-2(a) postponing

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the briefing deadlines with respect to EON’s Motion to Compel MSI to Produce Documents and

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Things (Dkt. No. 876), such that:
FOURTH JOINT STIPULATION TO EXTEND DEADLINES RE EON CORP. IP HOLDINGS, LLC’S
MOTION TO COMPEL MOTOROLA SOLUTIONS, INC. TO PRODUCE DOCUMENTS AND THINGS
CASE NO. C12-01011 JST (EDL)

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(1)

MSI’s Opposition to EON’s pending Motion to Compel shall be filed no later than

April 11, 2014,
(2)

EON’s Reply in support of its Motion to Compel shall be filed no later than April

18, 2014, and
(3)

The hearing for the Motion to Compel shall be remain scheduled on May 6, 2014,

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or any other day thereafter at the Court’s convenience.

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DATED: March 7, 2014

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Respectfully submitted,
KILPATRICK TOWNSEND & STOCKTON LLP

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By: /s/ Jessica L. Hannah

JESSICA L. HANNAH

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Attorneys for Defendant
MOTOROLA SOLUTIONS, INC.

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DATED: March 7, 2014

Respectfully submitted,
By:

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/s/ Chad Ennis
CHAD ENNIS
Attorneys for Plaintiff
EON Corp IP Holdings LLC

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PURSUANT TO STIPULATION, IT IS SO ORDERED:

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March 10
DATED: ___________________, 2014

Honorable Elizabeth D. Laporte
U.S.D.C. Magistrate Judge

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FOURTH JOINT STIPULATION TO EXTEND DEADLINES RE EON CORP. IP HOLDINGS, LLC’S MOTION TO COMPEL MOTOROLA
SOLUTIONS, INC. TO PRODUCE DOCUMENTS AND THINGS
CASE NO. C12-01011 JST (EDL)
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CERTIFICATION PURSUANT TO L.R. 5-1(i)(3)

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Pursuant to Local Rule 5-1(i)(3), I hereby certify that I have obtained the concurrence in

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the filing of this document from all the signatories for whom a signature is indicated by a

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“conformed” signature (/s/) within this e-filed document and I have on file records to support this

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concurrence for subsequent production for the Court if so ordered or for inspection upon request.

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Executed on March 7, 2014, at San Francisco, California.

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/s/ Jessica L. Hannah
JESSICA L. HANNAH

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5357245v.1

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FOURTH JOINT STIPULATION TO EXTEND DEADLINES RE EON CORP. IP HOLDINGS, LLC’S MOTION TO COMPEL MOTOROLA
SOLUTIONS, INC. TO PRODUCE DOCUMENTS AND THINGS
CASE NO. C12-01011 JST (EDL)
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