LSI Corporation v. Vizio, Inc.

Filing 13

STIPULATION AND ORDER re 12 STIPULATION WITH PROPOSED ORDER re 7 Order to Further Extend Briefing Schedule on LSI Corporation's Motion to Compel the Production of Documents and Deposition Testimony From Third-Party Zoran Corporation filed by Zoran Corporation. Signed by Judge James Ware on 2/28/12. (sis, COURT STAFF) (Filed on 2/28/2012)

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MICHAEL G. SCHWARTZ, Bar No. 197010
[e-mail]
ERIK R. FUEHRER, Bar No. 252578
[e-mail]
DLA PIPER LLP (US)
2000 University Avenue
East Palo Alto, CA 94303-2214
Tel: [phone]
Fax: [phone]

Wayne W. Call, Bar No. 56676
[e-mail]
Aaron L. Renfro, Bar No. 255086
[e-mail]
CALL & JENSEN
A Professional Corporation
610 Newport Center Drive, Suite 700
Newport Beach, CA 92660
Tel: [phone]; Fax: [phone]

Attorneys for Non-Party
Zoran Corporation

Herbert J. Hammond (Pro Hac Vice)
[e-mail]
THOMPSON & KNIGHT LLP
1722 Routh Street, Suite 1500
Dallas, TX 75201
Tel: [phone]; Fax: [phone]

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Attorneys for Plaintiff and Counterdefendant
LSI Corporation, dba LSI Logic Corporation

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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LSI CORPORATION, dba LSI Logic
Corporation,

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Plaintiff,

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(Central District Case No. SACV10-01602 AG
(AJWx))

v.
VIZIO, INC.,
Defendant.

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CASE NO. CV12 80021 JW MISC.

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STIPULATION AND [PROPOSED]
ORDER TO FURTHER EXTEND
BRIEFING SCHEDULE ON LSI
CORPORATION’S MOTION TO COMPEL
THE PRODUCTION OF DOCUMENTS
AND DEPOSITION TESTIMONY FROM
THIRD-PARTY ZORAN CORPORATION

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AND RELATED COUNTERCLAIMS

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DLA P IPER LLP (US)
EAST PALO ALTO

-1WEST\229525673.1

STIPULATION AND [PROPOSED] ORDER TO EXTEND BRIEFING SCHEDULE
CASE NO. CV12 80021 JW MISC

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Pursuant to Civil Local Rules 6-1, 6-2 and 7-12, IT IS HEREBY STIPULATED by and

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between Plaintiff LSI Corporation (“LSI”) and Non-party Zoran Corporation (“Zoran”), by and

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through their counsel of record, as follows:

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WHEREAS, on January 25, 2012, Plaintiff LSI filed a motion to compel the production of
documents and deposition testimony from third-party Zoran Corporation (“Motion to Compel”);

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WHEREAS, on February 3, 2012, the Court issued an order setting the following briefing
schedule for LSI’s Motion to Compel:

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Third-Party Zoran Corporation shall file its Opposition to Plaintiff’s Motion on or

before February 17, 2012; and

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2.

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WHEREAS, LSI and Zoran have met and conferred in good faith (through counsel) and

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have reached an agreement for Zoran to provide certain discovery that Zoran and LSI anticipate

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will alleviate the need for motion practice in this matter;

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WHEREAS, on February 21, 2012, Zoran and LSI filed a stipulation extending Zoran’s
opposition date to LSI’s motion to compel until February 24, 2012;

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Plaintiff LSI Corporation shall file its Reply on or before February 27, 2012;

WHEREAS, on February 22, 2012, the Court granted the parties’ stipulation to extend the
deadlines in its February 3, 2012 order;

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WHEREAS, the parties have further met and conferred and agreed to further extend the

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briefing deadlines for LSI’s Motion to Compel to allow Zoran to collect and provide the agreed

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upon discovery;

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WHEREAS, the parties have previously requested one extension of the briefing schedule
in their February 21, 2012 stipulation;

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WHEREAS, this is a miscellaneous action and the requested time modification, therefore,
will not effect the dates set by the Court other than as described above;

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The parties hereby STIPULATE to the following briefing schedule relating to LSI’s
Motion to Compel:


March 16, 2012 – Last Day for Zoran to file its Opposition to LSI’s Motion to Compel;

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DLA P IPER LLP (US)
EAST PALO ALTO

-2WEST\229525673.1

STIPULATION AND [PROPOSED] ORDER TO EXTEND BRIEFING SCHEDULE
CASE NO. CV12 80021 JW MISC

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

March 23, 2012 – Last Day for LSI to file is Reply;
SO STIPULATED.

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Dated: February 24, 2012
DLA PIPER LLP (US)

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By /s/ Michael G. Schwartz
MICHAEL G. SCHWARTZ
Attorneys for Non-Party
Zoran Corporation

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Dated: February 24, 2012

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THOMPSON & KNIGHT LLP

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By /s/ Herbert J. Hammond
HERBERT J. HAMMOND
Attorneys for Plaintiff and Counterdefendant
LSI Corporation, dba LSI Logic Corporation

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In accordance with General Order 45.X.B., Erik Fuehrer, counsel for Zoran Corporation,
attests that each other signatory listed above has concurred in this filing.

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DLA P IPER LLP (US)
EAST PALO ALTO

-3WEST\229525673.1

STIPULATION AND [PROPOSED] ORDER TO EXTEND BRIEFING SCHEDULE
CASE NO. CV12 80021 JW MISC

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[PROPOSED] ORDER

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GOOD CAUSE APPEARING, it is hereby ORDERED as follows:

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The Court adopts the Stipulation agreed to between Zoran and LSI with respect to the

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briefing schedule for LSI Corporation’s motion to compel the production of documents and

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deposition testimony from third-party Zoran Corporation (“Motion to Compel”).
The briefing and hearing schedule relating to LSI’s Motion to Compel shall be extended

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as follows:

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

March 16, 2012 – Last Day for Zoran to file its Opposition to LSI’s Motion to Compel;

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

March 23, 2012 – Last Day for LSI to file is Reply;

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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February 28, 2012
DATED: ______________________

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_________________________________
The Honorable James Ware
Chief United States District Court Judge

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DLA P IPER LLP (US)
EAST PALO ALTO

-4WEST\229525673.1

STIPULATION AND [PROPOSED] ORDER TO EXTEND BRIEFING SCHEDULE
CASE NO. CV12 80021 JW MISC