World Surveillance Group Inc v. La Jolla Cove Investors, Inc.

Filing 17

STIPULATION REGARDING UPCOMING EX PARTE MOTION HEARING AND TIME TO RESPOND TO COMPLAINT; ORDER re 16 STIPULATION WITH PROPOSED ORDER. Hearing as to 3 MOTION for Temporary Restraining Order shall be continued to 12/04/2013 at 2:00 p.m., opposit ion due 21 days in advance, reply due 14 days in advance. The due date for La Jollas response to WSGIs Complaint, by answer or motion, shall be extended until December 18, 2013. Signed by Judge William H. Orrick on 09/23/2013. (jmdS, COURT STAFF) (Filed on 9/23/2013)

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DLA PIPER LLP (US)
ROY K. MCDONALD, Bar No. 193691
[e-mail]
555 Mission Street, Suite 2400
San Francisco, CA 94105-2933
Telephone:
415.836.2500
Facsimile:
415.836.2501
Attorneys for Defendant
LA JOLLA COVE INVESTORS, INC.,

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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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WORLD SURVEILLANCE GROUP
INC., a Delaware Corporation,

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Plaintiff,

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v.

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STIPULATION REGARDING UPCOMING
EX PARTE MOTION HEARING AND
TIME TO RESPOND TO COMPLAINT;
ORDER

LA JOLLA COVE INVESTORS, INC., a
California corporation, and DOES 1-30

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Defendants.

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DLA P IPER LLP (US)
SAN FRA NCI S CO

CASE NO. 3:13-cv-03455 (WHO)

Plaintiff World Surveillance Group Inc. (“WSGI”) and Defendant La Jolla Cove
Investors, Inc. (“La Jolla”), by and through their counsel of record, hereby file the following
stipulation regarding the upcoming October 16, 2013 hearing of Plaintiff’s Motion for Temporary
Restraining Order and Order to Show Cause Regarding Preliminary Injunction (“Motion”) and
the time for La Jolla to respond to WSGI’s Complaint:
WHEREAS WSGI and La Jolla participated in private mediation of this matter with the
Honorable Edward Infante on September 17, 2013;
WHEREAS WSGI and La Jolla remain engaged in settlement discussions following the
mediation session;
WHEREAS both WSGI and La Jolla Cove have agreed that, in light of the ongoing
settlement discussions, the hearing and/or briefing on the scheduled Motion and La Jolla’s
response to WSGI’s Complaint should be further continued.
-1STIPULATION RE: HEARING AND RESPONSE TO COMPLAINT CASE NO. 3:13-cv-03455 (WHO)
WEST\242571881.1

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NOW, THEREFORE, WSGI and La Jolla stipulate to the following:

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pm, shall be continued to December 4, 2013 at 2:00 pm;
2.

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3.

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That WSGI’s Reply to La Jolla’s Opposition will be due fourteen (14) days prior
to the December 4, 2013 hearing date;

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That La Jolla’s Opposition to WSGI’s Motion will be due twenty-one (21) days
prior to the December 4, 2013 hearing date;

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That the hearing of the Motion currently scheduled for October 16, 2013 at 2:00

That the due date for La Jolla’s response to WSGI’s Complaint, by answer or
motion, shall be extended until December 18, 2013.

IT IS SO STIPULATED.
The parties hereby request that the Court affirm this stipulation by signing it pursuant to

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Local Rule 7-12.

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Dated: September 20, 2013

WEISBERG & MILLER

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By:
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Dated: September 20, 2013

/s/ Craig S. Miller
Craig S. Miller
Attorneys for Plaintiff
WORLD SURVEILLANCE GROUP, INC.

DLA PIPER LLP (US)

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By: /s/ Roy K. McDonald
ROY K. MCDONALD
Attorneys for Defendant
LA JOLLA COVE INVESTORS, INC

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I, Roy K. McDonald, am the ECF user whose ID and password are being used to file this

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STIPULATION REGARDING UPCOMING EX PARTE MOTION HEARING AND TIME TO

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RESPOND TO COMPLAINT; [PROPOSED] ORDER. In compliance with Local Rule 5-1(i)(3)
Herby attest that Craig S. Miller has given his concurrence as to the filing of this pleading.

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DLA P IPER LLP (US)
SAN FRA NCI S CO

-2STIPULATION RE: HEARING AND RESPONSE TO COMPLAINT CASE NO. 3:13-cv-03455 (WHO)
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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: September 23, 2013

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The Hon. District Judge William H. Orrick

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DLA P IPER LLP (US)
SAN FRA NCI S CO

-3STIPULATION RE: HEARING AND RESPONSE TO COMPLAINT CASE NO. 3:13-cv-03455 (WHO)
WEST\242571881.1