Circle Click Media LLC v. Regus Management Group LLC et al
Filing
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STIPULATION AND ORDER to Enlarge Time to Answer or Otherwise Respond to Defendants' Counterclaims and to Continue Case Management Conference. Case Management Statement due by 9/6/2013. Case Management Conference set for 9/13/2013 10:00 AM in Courtroom 1, 17th Floor, San Francisco. Signed by Judge Samuel Conti on 05/21/2013. (tmi, COURT STAFF) (Filed on 5/22/2013)
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GAROFOLO LAW GROUP, P.C.
Joseph A. Garofolo, California Bar No. 214614
E-mail: jgarofolo@garofololaw.com
90 New Montgomery Street, Suite 905
San Francisco, CA 94105
Telephone: (415) 981-8500
Facsimile: (415) 981-8870
ARI LAW, P.C.
Ali Aalaei, California Bar No. 254713
E-mail: ali@arilaw.com
Bo Zeng, California Bar No. 281626
E-mail: bozeng@arilaw.com
90 New Montgomery Street, Suite 905
San Francisco, CA 94105
Telephone: (415) 357-3600
Facsimile: (415) 357-3602
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Attorneys for Plaintiffs
CIRCLE CLICK MEDIA LLC, METRO
TALENT, LLC, and CTNY INSURANCE
GROUP LLC
BRYAN CAVE LLP
K. Lee Marshall, California Bar No. 277092
Meryl Macklin, California Bar No. 115053
Daniel Thomas Rockey, California Bar No. 178604
560 Mission Street, 25th Floor
San Francisco, CA 94105
Telephone:
(415) 675-3400
Facsimile:
(415) 675-3434
Email:
klmarshall@bryancave.com
meryl.macklin@bryancave.com
daniel.rockey@bryancave.com
Attorneys for Defendants
REGUS MANAGEMENT GROUP, LLC, REGUS
BUSINESS CENTRE, LLC, REGUS plc, and HQ
GLOBAL WORKPLACES LLC
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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CIRCLE CLICK MEDIA LLC, et al.,
Case No. 3:12-CV-04000 SC
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Plaintiffs,
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vs.
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REGUS MANAGEMENT GROUP, LLC,
et al.,
STIPULATION AND [PROPOSED]
ORDER TO ENLARGE TIME TO
ANSWER OR OTHERWISE RESPOND
TO DEFENDANTS’ COUNTERCLAIMS
AND TO CONTINUE CASE
MANAGEMENT CONFERENCE
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Defendants.
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STIPULATION AND [PROPOSED] ORDER
Case No. 3:12-CV-04000 SC
STIPULATION
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Pursuant to Civil L.R. 6-2, 7-12, and 16-12, Plaintiffs Circle Click Media LLC, Metro
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Talent, LLC, and CTNY Insurance Group LLC (collectively, “Plaintiffs”) and Defendants Regus
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Management Group, LLC, Regus Business Centre, LLC, Regus plc, and HQ Global Workplaces
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LLC (collectively, “Defendants”) hereby stipulate and request that the time for Plaintiffs to answer
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or otherwise respond to the Counterclaims (Doc. 78) of Regus Management Group, LLC (“RMG”)
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be enlarged until, and including, June 24, 2013. The parties also stipulate and request that the
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following briefing schedule be established for any motions to dismiss (“Motions to Dismiss”) that
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Plaintiffs intend to file by June 24, 2013: i) Defendant RMG’s oppositions thereto be due by, and
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including, July 15, 2013; and ii) Plaintiffs’ replies to Defendant’s oppositions be due by, and
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including, July 26, 2013. The parties further stipulate and request that the Plaintiffs may notice
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their Motions to Dismiss for August 9, 2013, at 10:00 A.M., and that the Case Management
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Conference, currently set for June 21, 2013, be continued to September 13, 2013, at 10:00 A.M.
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Plaintiffs filed their Second Amended Complaint (Doc. 65) on February 11, 2013, alleging
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a putative class action. After Defendants filed a motion to dismiss (Doc. 69), which the Court
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granted in part and denied in part pursuant to its Order dated April 22, 2013 (Doc. 77), Defendants
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timely filed their Answer, Affirmative Defenses, and Counterclaims (Doc. 78) on May 6, 2013.
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Absent an extension, an answer or other response would be due on May 28, 2013. (See
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Declaration of Joseph A. Garofolo ¶ 3 filed concurrently herewith). Plaintiffs currently intend to
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file motions to dismiss in response to some or all of the Counterclaims. (Id.).
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Plaintiffs’ lead counsel’s wife is expecting the birth of their third child (a second
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daughter) with a due date on May 20, 2013, and Plaintiffs’ lead counsel wishes to reduce some of
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the burden of his litigation schedule surrounding his wife’s due date to spend time with his family
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and new daughter. (See id. at ¶ 4).
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Accordingly, the parties have stipulated to the extended briefing schedule set forth above.
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The parties also believe that judicial economy may be achieved by continuing the Case
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Management Conference currently set for June 21, 2013, to September 13, 2013, which would be
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after the requested hearing on Plaintiffs’ Motions to Dismiss, and Plaintiffs’ counsel has a
- 2STIPULATION AND [PROPOSED] ORDER
Case No. 3:12-CV-04000 SC
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scheduling conflict with travel to and attendance at a wedding in which he is involved on the date
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currently set for the Case Management Conference of June 21, 2013. (See id. at ¶ 5). Plaintiffs
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request that they be permitted to file an updated joint Case Management Statement by September
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6, 2013 (seven days prior to the requested date for the continued Case Management Conference).
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Plaintiffs’ counsel has confirmed with the Court that August 9, 2013, at 10:00 A.M., is
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currently available for the Court to hear Plaintiffs’ Motions to Dismiss and September 13, 2013, at
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10:00 A.M., is available for a Case Management Conference. (See id. at ¶ 6).
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This is the first request for an enlargement of the time for Plaintiffs to answer or otherwise
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respond to the Counterclaims and the briefing schedule relating to the Motions to Dismiss, and the
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second request for a continuance of the Case Management Conference. (Id. at ¶ 7).
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- 3STIPULATION AND [PROPOSED] ORDER
Case No. 3:12-CV-04000 SC
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