Circle Click Media LLC v. Regus Management Group LLC et al

Filing 80

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)

Download PDF
1 2 3 4 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 5 6 7 8 9 10 11 12 13 14 15 16 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 17 UNITED STATES DISTRICT COURT 18 NORTHERN DISTRICT OF CALIFORNIA 19 20 CIRCLE CLICK MEDIA LLC, et al., Case No. 3:12-CV-04000 SC 21 Plaintiffs, 22 vs. 23 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 24 25 Defendants. 26 27 28 STIPULATION AND [PROPOSED] ORDER Case No. 3:12-CV-04000 SC STIPULATION 1 2 Pursuant to Civil L.R. 6-2, 7-12, and 16-12, Plaintiffs Circle Click Media LLC, Metro 3 Talent, LLC, and CTNY Insurance Group LLC (collectively, “Plaintiffs”) and Defendants Regus 4 Management Group, LLC, Regus Business Centre, LLC, Regus plc, and HQ Global Workplaces 5 LLC (collectively, “Defendants”) hereby stipulate and request that the time for Plaintiffs to answer 6 or otherwise respond to the Counterclaims (Doc. 78) of Regus Management Group, LLC (“RMG”) 7 be enlarged until, and including, June 24, 2013. The parties also stipulate and request that the 8 following briefing schedule be established for any motions to dismiss (“Motions to Dismiss”) that 9 Plaintiffs intend to file by June 24, 2013: i) Defendant RMG’s oppositions thereto be due by, and 10 including, July 15, 2013; and ii) Plaintiffs’ replies to Defendant’s oppositions be due by, and 11 including, July 26, 2013. The parties further stipulate and request that the Plaintiffs may notice 12 their Motions to Dismiss for August 9, 2013, at 10:00 A.M., and that the Case Management 13 Conference, currently set for June 21, 2013, be continued to September 13, 2013, at 10:00 A.M. 14 Plaintiffs filed their Second Amended Complaint (Doc. 65) on February 11, 2013, alleging 15 a putative class action. After Defendants filed a motion to dismiss (Doc. 69), which the Court 16 granted in part and denied in part pursuant to its Order dated April 22, 2013 (Doc. 77), Defendants 17 timely filed their Answer, Affirmative Defenses, and Counterclaims (Doc. 78) on May 6, 2013. 18 Absent an extension, an answer or other response would be due on May 28, 2013. (See 19 Declaration of Joseph A. Garofolo ¶ 3 filed concurrently herewith). Plaintiffs currently intend to 20 file motions to dismiss in response to some or all of the Counterclaims. (Id.). 21 Plaintiffs’ lead counsel’s wife is expecting the birth of their third child (a second 22 daughter) with a due date on May 20, 2013, and Plaintiffs’ lead counsel wishes to reduce some of 23 the burden of his litigation schedule surrounding his wife’s due date to spend time with his family 24 and new daughter. (See id. at ¶ 4). 25 Accordingly, the parties have stipulated to the extended briefing schedule set forth above. 26 The parties also believe that judicial economy may be achieved by continuing the Case 27 Management Conference currently set for June 21, 2013, to September 13, 2013, which would be 28 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 1 scheduling conflict with travel to and attendance at a wedding in which he is involved on the date 2 currently set for the Case Management Conference of June 21, 2013. (See id. at ¶ 5). Plaintiffs 3 request that they be permitted to file an updated joint Case Management Statement by September 4 6, 2013 (seven days prior to the requested date for the continued Case Management Conference). 5 Plaintiffs’ counsel has confirmed with the Court that August 9, 2013, at 10:00 A.M., is 6 currently available for the Court to hear Plaintiffs’ Motions to Dismiss and September 13, 2013, at 7 10:00 A.M., is available for a Case Management Conference. (See id. at ¶ 6). 8 This is the first request for an enlargement of the time for Plaintiffs to answer or otherwise 9 respond to the Counterclaims and the briefing schedule relating to the Motions to Dismiss, and the 10 second request for a continuance of the Case Management Conference. (Id. at ¶ 7). 11 /// 12 /// 13 /// 14 /// 15 /// 16 /// 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// - 3STIPULATION AND [PROPOSED] ORDER Case No. 3:12-CV-04000 SC NO R NIA S UNIT ED RT U O onti H LI RT ER FO amuel C Judge S A 21 S DISTRICT TE C TA N F D IS T IC T O R C

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?