Mount Hamilton Partners LLC v. Groupon Inc.

Filing 103

ORDER Further Case Management Conference set for 2/26/14 is continued to 3/14/2014 03:00 PM in Courtroom 10, 19th Floor, San Francisco.. Signed by Judge Susan Illston on 2/11/14. (tfS, COURT STAFF) (Filed on 2/12/2014)

1 James T. Hultquist (pro hac vice)
2
3
4
5

[e-mail]
Khurram N. Gore (pro hac vice)
Adrian Shin (CA State Bar No. 256960)
REED SMITH LLP
101 Second Street, Suite 1800
San Francisco, CA 94105-3659
Telephone: [phone]
Facsimile: [phone]

6
Attorneys for Defendant

Jenna F. Karadbil
[e-mail]
California State Bar No. 213574
PILLSBURY WINTHROP SHAW
PITTMAN LLP
1540 Broadway
New York, New York 10036
Telephone: [phone]
Facsimile: [phone]
Callie A. Bjurstrom
[e-mail]
California State Bar No. 137816
PILLSBURY WINTHROP SHAW
PITTMAN LLP
501 West Broadway
San Diego, California 92101
Telephone: [phone]
Facsimile: [phone]

7 GROUPON, INC.
8
9
10
11
12

Attorneys for Plaintiff
MOUNT HAMILTON PARTNERS, LLC

13
14

UNITED STATES DISTRICT COURT

15

NORTHERN DISTRICT OF CALIFORNIA

16
SAN FRANCISCO DIVISION

17
18 MOUNT HAMILTON PARTNERS, LLC,
19
20

Plaintiff/Counterdefendant,
v.

21
GROUPON, INC.,

22
23

Case No. 3:12-CV-1700-SI

STIPULATION AND [PROPOSED]
ORDER CONTINUING FURTHER CASE
MANAGEMENT CONFERENCE
[Civ. L.R. 6-2 & 7-12]

Defendant/Counterclaimant.

24
25
26
27
28
Case No. C-12-1700
STIPULATION AND [PROPOSED] ORDER CONTINUING FURTHER CASE MANAGEMENT CONFERENCE

1

Pursuant to Local Rules 6-2 and 7-12, Plaintiff Mount Hamilton Partners, LLC (“MHP” or

2 “Plaintiff”) and Defendant Groupon, Inc. (“Groupon”), by and through their respective
3 undersigned counsel, hereby jointly move the Court for an order continuing the scheduled date for
4 a Further Case Management Conference, for the following reasons:
5

1.

Pursuant to this Court’s January 22, 2014 Notice Continuing Further Case

6 Management Conference (Dkt. No. 101), the parties are scheduled to participate in a Further Case
7 Management Conference on February 26, 2014.
8

2.

Due to scheduling conflicts, counsel for Groupon and MHP are both unavailable on

9 February 26, 2014. Counsel for Plaintiff and Groupon join in the request for continuing the date
10 for the Further Case Management Conference to the next available date on the Court’s calendar.
11

3.

Accordingly, the parties hereby stipulate to and request the Court to continue the

12 Further Case Management Conference from February 26 to March 14, 2013 at 3:00 p.m. or such
13 other date and time that is agreeable with the Court’s calendar. The requested continuance does
14 not affect any other deadline ordered by the Court.
15
16

Dated: February 10, 2014

17
By:

18
19

/s/ Khurram Nasir Gore
JAMES T. HULTQUIST
KHURRAM NASIR GORE
ADRIAN SHIN

20
Attorneys for Plaintiff
GROUPON, INC.

21
22 Dated: February 10, 2014
23
24
25
26
27

By:

/s/ Jenna F. Karadbil
CALLIE A. BJURSTROM
JENNA F. KARADBIL
Attorneys for Defendant
MOUNT HAMILTON PARTNERS, LLC

28
Case No. C-12-1700
-2STIPULATION AND [PROPOSED] ORDER CONTINUING FURTHER CASE MANAGEMENT CONFERENCE

1
2

PURSUANT TO STIPULATION, IT IS SO ORDERED.
Feb 11

Dated: ___________, 2014

3
4
HONORABLE SUSAN ILLSTON
UNITED STATES DISTRICT COURT JUDGE

5
6
7
8
9

SIGNATURE ATTESTATION

I, Khurram Nasir Gore, hereby attest, pursuant to N.D. Cal. General Order No. 45,

10 that the concurrence to the filing of this document has been obtained from each signatory
11 hereto.
12
13 Dated: February 10, 2014

REED SMITH LLP

14
15
16
17

By: /s/ Khurram Nasir Gore
Khurram Nasir Gore
Attorneys for Defendant
GROUPON, INC.

18
19
20
21
22
23
24
25
26
27
28
Case No. C-12-1700
-3STIPULATION AND [PROPOSED] ORDER CONTINUING FURTHER CASE MANAGEMENT CONFERENCE

1 James T. Hultquist (pro hac vice)
[e-mail]
2 Khurram N. Gore (pro hac vice)
Adrian Shin (CA State Bar No. 256960)
3 REED SMITH LLP
101 Second Street, Suite 1800
4 San Francisco, CA 94105-3659
Telephone: [phone]
5 Facsimile: [phone]

Jenna F. Karadbil
[e-mail]
California State Bar No. 213574
PILLSBURY WINTHROP SHAW
PITTMAN LLP
1540 Broadway
New York, New York 10036
Telephone: [phone]
Facsimile: [phone]

6 Attorneys for Defendant
GROUPON, INC.
7

Callie A. Bjurstrom
[e-mail]
California State Bar No. 137816
PILLSBURY WINTHROP SHAW
PITTMAN LLP
501 West Broadway
San Diego, California 92101
Telephone: [phone]
Facsimile: [phone]

8
9

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10

Attorneys for Plaintiff
MOUNT HAMILTON PARTNERS, LLC

11
12
13

UNITED STATES DISTRICT COURT

14

NORTHERN DISTRICT OF CALIFORNIA

15

SAN FRANCISCO DIVISION

16
17
MOUNT HAMILTON PARTNERS, LLC,

Case No. 3:12-CV-1700-SI

18
Plaintiff/Counterdefendant,
19
v.
20
GROUPON, INC.,

DECLARATION OF KHURRAM NASIR
GORE IN SUPPORT OF STIPULATION
AND [PROPOSED] ORDER CONTINUING
FURTHER CASE MANAGEMENT
CONFERENCE

21
Defendant/Counterclaimant.

[Civ. L.R. 6-2 & 7-12]

22
23
24
25
26
27
28

-1-

Case No. C-12-1700
DECLARATION OF GORE IN SUPPORT STIPULATION AND [PROPOSED] ORDER
CONTINUING FURTHER CASE MANAGEMENT CONFERENCE
US_ACTIVE-116396892.1-KNGORE 02/10/2014 3:44 PM

1

I, Khurram Nasir Gore, declare:

2

1.

I am an associate with Reed Smith LLP, counsel for Defendant Groupon, Inc.

3 (“Groupon”), in the above-captioned action. The contents of this declaration are based upon my
4 personal knowledge and are true and correct to the best of my knowledge and belief. If called upon
5 I could and would testify competently thereto.
6

2.

Pursuant to this Court’s January 22, 2014 Notice Continuing Further Case

7 Management Conference (Dkt. No. 101), the parties are scheduled to participate in a Further Case
8 Management Conference on February 26, 2014.

REED SMITH LLP

3.

Counsel for Groupon is unavailable on February 26, 2014.

10
A limited liability partnership formed in the State of Delaware

9

4.

I have conferred with counsel for Plaintiff Mount Hamilton Partners, LLC

11 (“MHP”), and counsel for MHP is also unavailable on February 26, 2014.
12

4.

Accordingly, the parties hereby stipulate to and request the Court to continue the

13 Further Case Management Conference from February 26 to March 14, 2014 at 3:00 p.m. or such
14 other date and time that is agreeable with the Court’s calendar. The requested continuance does
15 not affect any other deadline ordered by the Court.
16

I declare under penalty of perjury of the laws of the United States of America that the

17 foregoing is true and correct.
18
19

DATED: February 10, 2014.

20
21

By /s/ Khurram Nasir Gore
Khurram Nasir Gore

22
23
24
25
26
27
28
-2-

Case No. C-12-1700
DECLARATION OF GORE IN SUPPORT STIPULATION AND [PROPOSED] ORDER
CONTINUING FURTHER CASE MANAGEMENT CONFERENCE