Skynet Electronic Co., Ltd v. Flextronics International, LTD.

Filing 57

ORDER GRANTING STIPULATED EXTENSION by Hon. William Alsup granting 56 Stipulation.(whalc1, COURT STAFF) (Filed on 7/10/2013)

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John B. Sullivan (State Bar No. 96742)
[e-mail]
Harold R. Jones (State Bar No. 209266)
[e-mail]
SEVERSON & WERSON
A Professional Corporation
One Embarcadero Center, Suite 2600
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
(additional counsel listed on signature page)

James L. Weinberg
(Admitted Pro Hac Vice)
[e-mail]
Thomas L. Anastos
(Admitted Pro Hac Vice)
[e-mail]
ULMER & BERNE LLP
1660 West 2nd Street, Suite 1100
Cleveland, Ohio 44113-1448
Telephone: [phone]
Facsimile: [phone]

Attorneys for Defendants and CounterClaimants
FLEXTRONICS INTERNATIONAL LTD. AND
POWER SYSTEMS TECHNOLOGIES LTD.

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DANIEL J. BERGESON, Bar No. 105439
[e-mail]
JAIDEEP VENKATESAN, Bar No. 211386
[e-mail]
KYUNG M. LEE, Bar No. 262128
[e-mail]
BERGESON, LLP
303 Almaden Boulevard, Suite 500
San Jose, CA 95110-2712
Telephone: [phone]
Facsimile: [phone]

ANDREWS KURTH LLP
Frederick S. Frei (Pro Hac Vice)
[e-mail]
Sean S. Wooden (Pro Hac Vice)
[e-mail]
Leasa Woods Anderson (Pro Hac Vice)
[e-mail]
1350 I Street NW, Suite 1100
Washington, DC 20005
Telephone: [phone]
Facsimile: [phone]

Counsel for Plaintiff/Counter-Defendant
SKYNET ELECTRONIC CO., LTD.

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO DIVISION

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SKYNET ELECTRONIC CO. LTD.,

Case No. CV12-06317 WHA

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Plaintiff,
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v.
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FLEXTRONICS INTERNATIONAL LTD. et
al.
Defendants.
AND RELATED COUNTERCLAIMS

STIPULATION AND [PROPOSED]
ORDER FOR AN EXTENSION OF TIME
TO RESPOND TO SECOND AMENDED
COMPLAINT
Judge: William A. Alsup
Courtroom 8, 19th Floor
Case Filed: December 12, 2012
Trial Date: September 8, 2014

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12334.0002/2790786.1 STIPULATION AND [PROPOSED] ORDER FOR AN
EXTENSION OF TIME TO RESPOND TO SECOND AMENDED COMPLAINT

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Pursuant to Civil Local Rules 6-2, 7-12, and related rules, Plaintiff Skynet Electronic Co.,

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Ltd. (“Skynet”) and Defendants Flextronics International, Ltd. (“Flextronics”) and Power

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Systems Technologies Ltd. (“Power Systems”) (collectively, “Defendants”) hereby stipulate

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through their respective counsel of record as follows:

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1.

Plaintiff Skynet filed its Second Amended Complaint on July 3, 2013. The

Second Amended Complaint names Defendants Flextronics and Power Systems.

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2.

Inasmuch as the parties have agreed that an orderly schedule for any response to

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the Second Amended Complaint would be efficient for the parties and for the Court, Defendants

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Flextronics and Power Systems shall, as permitted by Federal Rule of Civil Procedure 12,

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answer, move or otherwise plead in response to the Second Amended complaint in the above-

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captioned action no later than July 31, 2013. The parties agree to confer before said date and to

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request the Court to enter an appropriate order if additional response time is needed.

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3.

Plaintiff Skynet and Defendants further stipulate and agree that entry into this

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stipulation by the Defendants shall not constitute a waiver of any jurisdictional or other defenses

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that may be available under Rule 12 of the Federal Rules of Civil Procedure, a waiver of any

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affirmative defenses under Rule 8 of the Federal Rules of Civil Procedure, or a waiver of any

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other statutory or common law defenses that may be available to the Defendants collectively or

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individually. Defendants expressly reserve their rights to raise any such defenses in response to

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either the current Second Amended Complaint or any amended pleading that may be filed

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relating to this action.

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4.

The time for Flextronics to respond to Skynet’s Amended Complaint was

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previously extended from January 7, 2013 to January 31, 2013. The deadline for filing requests

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for leave to file pleading amendments was previously modified from June 28, 2013 to August 27,

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2013. There have been no other extensions of time in this matter.

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5.

No case management deadlines will be affected by this stipulation.

X

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12334.0002/2790786.1

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STIPULATION AND [PROPOSED] ORDER FOR AN
EXTENSION OF TIME TO RESPOND TO SECOND AMENDED COMPLAINT

CASE NO. C12-06317 WHA

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STIPULATED TO AND APPROVED BY:

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DATED: July 10, 2013

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/s/ Harold R. Jones
John B. Sullivan (CSB No. 96742)
Harold R. Jones (CSB No. 209266)
Eric J. Gribbin (CSB No. 205877)
[e-mail]
ULMER & BERNE LLP
500 W. Madison Street, Suite 3600
Chicago, IL 60661-4587
Telephone: [phone]
Facsimile: [phone]

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James L. Weinberg
(Admitted Pro Hac Vice)
[e-mail]
Thomas L. Anastos
(Admitted Pro Hac Vice)
[e-mail]
ULMER & BERNE LLP
1660 West 2nd Street, Suite 1100
Cleveland, Ohio 44113-1448
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendants and CounterClaimants Flextronics International, Ltd. and
Power Systems Technologies, Ltd.

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12334.0002/2790786.1

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STIPULATION AND [PROPOSED] ORDER FOR AN
EXTENSION OF TIME TO RESPOND TO SECOND AMENDED COMPLAINT

CASE NO. C12-06317 WHA

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In accordance with Civil Local Rule 5-1(i)(3), the above signatory attests that
concurrence in the signing of this document has been obtained from the signatory below.

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DATED: July 10, 2013

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/s/ Jaideep Venkatesan
BERGESON, LLP
Daniel J. Bergeson
Jaideep Venkatesan
Kyung M. Lee
303 Almaden Blvd., Suite 500
San Jose, CA 95110-2712
Telephone: [phone]
Facsimile: [phone]
ANDREWS KURTH LLP
Frederick S. Frei
(Admitted Pro Hac Vice)
[e-mail]
Leasa Woods Anderson
(Admitted Pro Hac Vice)
[e-mail]
1350 I Street NW, Suite 1100
Washington, DC 20005
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff
Skynet Electronic Co., Ltd.

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IT IS SO ORDERED

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Dated: July 10_, 2013
_
William Alsup
United States District Judge

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12334.0002/2790786.1

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STIPULATION AND [PROPOSED] ORDER FOR AN
EXTENSION OF TIME TO RESPOND TO SECOND AMENDED COMPLAINT

CASE NO. C12-06317 WHA