Levi Strauss & CO v. Mother LLC

Filing 9

ORDER re 8 Status Report filed by Levi Strauss & CO. Signed by Chief Magistrate Judge Maria-Elena James on 12/20/2012. (rmm2S, COURT STAFF) (Filed on 12/20/2012)

1
2
3
4

KILPATRICK TOWNSEND & STOCKTON LLP
GREGORY S. GILCHRIST (Bar # 111536)
GIA L. CINCONE (Bar # 141668)
Two Embarcadero Center, 8th Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail], [e-mail]

5
6

Attorneys for Plaintiff
LEVI STRAUSS & CO.

7
8

UNITED STATES DISTRICT COURT

9

FOR THE NORTHERN DISTRICT OF CALIFORNIA

10
11

LEVI STRAUSS & CO.,

12

Case No. C 12-04396 MEJ

Plaintiff,

13
14

JOINT STATUS REPORT AND
[PROPOSED] ORDER

v.
MOTHER LLC,

15

Defendant.

16
17
18

Pursuant to the Court’s December 10, 2012, Order (Docket 7), Plaintiff Levi Strauss & Co.

19

(“LS&Co.”) and Defendant Mother LLC (“Mother”) hereby submit this joint status report and

20

proposed order.

21

Counsel for Mother agreed on October 23, 2012, to accept service of LS&Co.’s Complaint.

22

Pursuant to several agreements between the parties for extensions of time, Mother has not yet

23

responded to the Complaint.

24

The parties have been engaged in settlement discussions since the filing of the Complaint and

25

have exchanged drafts of a settlement agreement. The parties expect they will be able to determine

26

within the next 30 days whether they will be able to reach an amicable resolution of this dispute.

27

Accordingly, the parties respectfully propose the following:

28
JOINT STATUS REPORT

-1-

Levi Strauss & Co. v. Mother LLC
Case No. C 12-04396 MEJ

1
2
3

1.

Mother is granted a further extension of time to January 7, 2013, to respond to the

Complaint.
2.

The Initial Case Management Conference in this matter shall be rescheduled for

4

January 17, 2013, and the accompanying deadlines set forth in the Court’s initial case management

5

scheduling order shall be continued accordingly.

6
7

The parties stipulate and agree that no further continuances of these deadlines shall be
requested.

8
9

DATED: December 19, 2012

Respectfully submitted,

10
By: ___/Gia L. Cincone/___
Gia L. Cincone
KILPATRICK TOWNSEND & STOCKTON LLP
Two Embarcadero Center, Eighth Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]

11
12
13
14

Attorneys for Plaintiff
LEVI STRAUSS & CO.

15
16
17

By: ___/Michael R. Heimbold/___
Michael R. Heimbold
Steptoe & Johnson LLP
2121 Avenue of the Stars, Suite 2800
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]

18
19
20
21

Attorneys for Defendant
MOTHER LLC

22
23
24

IT IS SO ORDERED.

25
26

December 20, 2012
Dated: ________________________

27

___________________________________
Hon. Maria-Elena James
United States Magistrate Judge

28
JOINT STATUS REPORT

-2-

Levi Strauss & Co. v. Mother LLC
Case No. C 12-04396 MEJ