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

Filing 19

STIPULATION REGARDING UPCOMING EX PARTE MOTION HEARING AND TIME TO RESPOND TO COMPLAINT re 18 STIPULATION WITH PROPOSED ORDER. Motion hearing shall be continued to January 8, 2014 at 2:00 pm; La Jolla's Opposition will be due twenty-one (2 1) days prior to the hearing date; WSGI's Reply will be due fourteen (14) days prior to the hearing date; the due date for La Jolla's response to WSGI's Complaint, by answer or motion, shall be extended until January 22, 2014. Signed by Judge William H. Orrick on 11/04/2013. (jmdS, COURT STAFF) (Filed on 11/4/2013)

1

4

Craig S. Miller (State Bar No. No. 139682)
William S. Weisberg (State Bar No. 146284)
WEISBERG & MILLER
654 Sacramento Street, Third Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile:
[phone]

5

Attorneys for Plaintiff

2
3

6
7
8

UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA

LAW OFFICES OF

WEISBERG & MILLER

654 SACRAMENTO STREET  THIRD FLOOR  SAN FRANCISCO  CA 94111
PHONE 4152967070 FAX 4152967060

10
11
12

WORLD SURVEILLANCE GROUP, INC.,
a Delaware Corporation,

13

Plaintiff,

14

vs.

15
16
17
18
19
20
21
22
23
24
25
26
27

LA JOLLA COVE INVESTORS, INC.,
a California corporation,

Case No. 3:13-cv-03455 (WHO)
STIPULATION REGARDING UPCOMING
EX PARTE MOTION HEARING AND
TIME TO RESPOND TO COMPLAINT;
ORDER
Current Hearing Date: December 4, 2013
Time: 2:00 p.m.
Floor/Court: 17, Ct. Rm. 2

DOES 1-30,
Defendants.
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 December 4, 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;

28
Page 1 of 4
STIPULATION RE : HEARING AND RESPONSE TO COMPLAINT

Case No. 3 :13-CV-03455 (WHO)

1

WHEREAS both WSGI and La Jolla have agreed that, in light of the ongoing settlement

2

discussions, the hearing and briefing on the schedule Motion and La Jolla’s response to WSGI’s

3

Complaint should be further continued to allow those settlement discussions to keep going;

4
5
6
7
8
9

LAW OFFICES OF

WEISBERG & MILLER

654 SACRAMENTO STREET  THIRD FLOOR  SAN FRANCISCO  CA 94111
PHONE 4152967070 FAX 4152967060

10
11
12
13
14
15
16
17
18
19

WHEREAS counsel for WSGI has confirmed the availability of the Court for a January
8, 2014 hearing at 2:00 pm.
NOW, THEREFORE, WSGI and La Jolla stipulate to the following:
1. That the hearing of the Motion currently scheduled for December 4, 2013 at 2:00 pm,
shall be continued to January 8, 2014 at 2:00 pm;
2. That La Jolla’s Opposition to WSGI’s Motion will be due twenty-one (21) days prior to
the January 8, 2014 hearing date;
3. That WSGI’s Reply to La Jolla’s Opposition will be due fourteen (14) days prior to the
January 8, 2014 hearing date;
4. That the due date for La Jolla’s response to WSGI’s Complaint, by answer or motion,
shall be extended until January 22, 2014.
IT IS SO STIPULATED.
The parties hereby request that the Court affirm this stipulation by signing it pursuant to
Local Rule 7-12.
WEISBERG & MILLER
Dated: October 31, 2013
By:

20
21
22
23
24
25
26
27

__/s/ Craig S. Miller_____________
Craig S. Miller,
Attorneys for WSGI
DLA PIPER LLP (US)

Dated: October 31, 2013
By:

__/s/ Roy K. McDonald__________
Roy K. McDonald,
Attorneys for La Jolla

I, Craig S. Miller, am the ECF user whose ID and password are being used to file this
STIPULATION REGARDING UPCOMING EX PARTE MOTION HEARING AND TIME TO
RESPOND TO COMPLAINT; [PROPOSED] ORDER. In compliance with Local Rule 5-1(i)(3)
hereby attest that Roy K. McDonald has given his concurrence as to the filing of this pleading.

28
Page 2 of 4
STIPULATION RE : HEARING AND RESPONSE TO COMPLAINT

Case No. 3 :13-CV-03455 (WHO)

1

PURSUANT TO STIPULATION, IT IS SO ORDERED

2
3
4

November 4
Dated: _______________________, 2013

__________________________________
The Hon. District Judge William H. Orrick

5
6
7
8
9

LAW OFFICES OF

WEISBERG & MILLER

654 SACRAMENTO STREET  THIRD FLOOR  SAN FRANCISCO  CA 94111
PHONE 4152967070 FAX 4152967060

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Page 3 of 4
STIPULATION RE : HEARING AND RESPONSE TO COMPLAINT

Case No. 3 :13-CV-03455 (WHO)