Perfect 10, Inc. v. Yandex N.V.
Filing
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STIPULATION AND ORDER TO MODIFY DEADLINES re 15 Stipulation filed by Yandex N.V.. Signed by Judge Alsup on April 20, 2012. (whalc1, COURT STAFF) (Filed on 4/20/2012)
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Eric J. Benink, Esq., SBN 187434
I Krause Kalfayan Benink & Slavens, LLP
2 550 West C Street, Suite 530
3 San Diego, CA 92101
(619) 232-0331 (ph)
4 (619) 232-4019 (fax)
eric@kkbs-law.com
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6 Attorneys for Plaintiff Perfect 10, Inc.
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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PERFECT 10, INC., a California
corporation,
Plaintiff,
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CASE NO. CV 12 1521 WHA
STIPULATION AND ORDER
STIPULATION TO MODIFY
TO MODIFY DEADLINES
DEADLINES
V.
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YANDEX N.V., a Netherlands limited
liability company, and DOES 1 through
16' 100, inclusive, inclusive,
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Defendants.
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CTRM: 8
JUDGE: William Alsup
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Plaintiff Perfect 10, Inc. ("Perfect 10") and Defendant Yandex N.V. ("Yandex")
by and through their attorneys, hereby stipulate pursuant to Local Rules 6.1 and 6.2 as
follows:
Whereas, the parties entered into an initial stipulation regarding a partial case
schedule on April 13, 2012; and
Whereas that stipulation advised the Court that the parties were working in good
faith to set a more complete schedule for the case, the results of which negotiations are
1 reflected in this stipulation; and
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Whereas, Quinn Emanuel Urquhart & Sullivan was engaged as counsel to
3 Yandex on April 11, 2012 and was provided with a copy of the filings in this action on
4 April 16, 2012; and
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Whereas, Yandex has agreed not to challenge the sufficiency of the service of
6 process of the summons and complaint or of the Motion for Preliminary Injunction; and
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Whereas, assuming the summons and complaint were properly served, Yandex's
8 response to the complaint is presently due on Monday April 23, 2012; and
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Whereas, Yandex is a foreign corporation whose officers reside abroad, are
10 unfamiliar with United States law and for whom English is at most a second language
11 and seek additional time to understand and assess the case as presented; and
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Whereas, Perfect 10 has agreed that counsel for Yandex should have further
13 additional time to respond to the complaint and Motion for Preliminary Injunction; and
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Whereas the parties have reached an agreement that does not alter any deadlines
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THEREFORE IT IS STIPULATED AND AGREED:
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1.
that Yandex's responsive pleading to the complaint shall be filed and
18 served on or before May 14, 2012; and
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2.
that Yandex's opposition to the pending Motion for Preliminary Injunction
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2.
that Perfect 10's reply (if any) in support of the Motion for Preliminary
22 Injunction shall be filed and served on or before June 4, 2012; and
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3.
the hearing on the Montion for Preliminary Injunction shall be continued
24 from May 24, 2012 to June 14, 2012 or as otherwise set by the Court;
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4.
that Yandex shall not challenge the sufficiency of the service of either the
26 summons and complaint or of the Motion for Preliminary Injunction; and
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6.
that neither this Stipulation nor Yandex's waiver of a challenge to the
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STIPULTION TO MODIFY DEADLINES
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service of the summons and Motion shall be deemed a general appearance by Yandex.
2 Yandex expressly preserves its defenses and objections to this action, including those
3 based on jurisdiction, venue, and forum non conveniens.
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6 IT IS SO STIPULATED.
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KRAUSE KALFAYAN BENINK
& SLAVENS, LLP.
DATED: April 18, 2012
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Eric J. Benink
Attorneys for Perfect 10, Inc.
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DATED: April 18, 2012
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
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f ~t~
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Di
oolittle
Attorneys for Yandex, N.V.
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18 PURSUANT TO STIPULATION, IT IS SO ORDERED.
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20 DATED:
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April 19, 2012.
William Alsup
United States District Judge
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STIPULTION TO MODIFY DEADLINES
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