Voicemail Club, Inc. v. Enhanced Services Billing, Inc

Filing 9

STIPULATION AND ORDER GRANTING STIPULATION AND CONTINUING CASE MANAGEMENT CONFERENCE. Signed by Magistrate Judge Maria-Elena James on 6/26/2012. (rmm2, COURT STAFF) (Filed on 6/26/2012)

1 BRUCE N. FURUKAWA (State Bar No. 157303)
[e-mail]
2 PHILIP BARILOVITS (State Bar No. 199944)
[e-mail]
3 VERITA J. MOLYNEAUX (State Bar No. 250875)
[e-mail]
4 SEVERSON & WERSON
A Professional Corporation
5 One Embarcadero Center, Suite 2600
San Francisco, California 94111
6 Telephone: [phone]
Facsimile: [phone]
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Attorneys for Defendant
8 ENHANCED SERVICES BILLING, INC.
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA — SAN FRANCISCO DIVISION

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13 VOICEMAIL CLUB, INC., a California
corporation,
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Plaintiff,
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vs.
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ENHANCED SERVICES BILLING, INC., a
17 Delaware corporation,
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Case No. CV 12 2189 MEJ
JOINT STIPULATION TO POSTPONE
RESPONSIVE PLEADING TO
COMPLAINT
The Honorable Maria-Elena James

Defendant.

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IT IS HEREBY STIPULATED by and between the parties, through their respective

21 counsel of record, that the response of Defendant Enhanced Services Billing, Inc. (“Defendant”) to
22 the complaint of Plaintiff Voicemail Club, Inc. (“Plaintiff”) may be filed on or before June 29,
23 2012.
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The parties agree that a continuance is appropriate because counsel has undertaken initial

25 meet and confer discussions regarding proper jurisdiction and venue, amendment of the complaint,
26 and/or re-filing of portions of the complaint under seal pursuant to L.R. 79-5.
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The parties further request that, because of the nature of the ongoing meet and confer

28 discussions, the Case Management Conference, currently scheduled for July 28, 2012, be
12077.0007/2250265.1

CV 12 2189 MEJ
1
JOINT STIPULATION TO POSTPONE RESPONSIVE PLEADING TO COMPLAINT

1 continued to August 31, 2012 or to a date thereafter that is convenient to the Court’s calendar.
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Pursuant to Civil Local Rule 6-1(a), a stipulation extending the time within which to

3 answer or otherwise respond to a complaint in an action is permitted without order of the Court,
4 provided the extension will not alter the date of any event or any deadline already fixed by Court
5 order.
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This stipulation will not alter any Court imposed date or deadline and is without prejudice

7 to the rights, claims, defenses and arguments of all parties.
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9 DATED: June 25, 2012

SEVERSON & WERSON
A Professional Corporation

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By:

/s/ Verita J. Molyneaux
Verita J. Molyneax
Attorneys for Defendant
ENHANCED SERVICES BILLING, INC.

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15 DATED: June 25, 2012

DICKS & WORKMAN, APC

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By:

/s/ Joseph G. Dicks
Joseph G. Dicks
Attorneys for Plaintiff
VOICEMAIL CLUB, INC.

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The Case Management Conference
is continued to September 6,
2012 at 10:00 a.m., Courtroom B,
15th Floor. Case Management
Statements are due August 30,
2012 and shall be E-filed with the
Court.
Dated: 6/26/2012

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12077.0007/2250265.1

CV 12 2189 MEJ
2
JOINT STIPULATION TO POSTPONE RESPONSIVE PLEADING TO COMPLAINT

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ATTESTATION OF SIGNATURE
(N.D. Cal General Order 45)

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I, Verita J. Molyneaux, hereby attest that concurrence in the filing of the

4 following document: JOINT STIPULATION TO POSTPONE RESPONSIVE
5 PLEADING TO COMPLAINT has been obtained from all of the signatories.
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7 Dated: June 25, 2012
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/s/ Verita J. Molyneaux_______________

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12077.0007/2250265.1

CV 12 2189 MEJ
3
JOINT STIPULATION TO POSTPONE RESPONSIVE PLEADING TO COMPLAINT