BWP Media USA, Inc. v. Shoptap, Inc.

Filing 13

ORDER Granting Request to Extend Time to Respond to Complaint and Continue CMC. Case Management Statement due by 5/15/2014. Case Management Conference set for 5/22/2014 10:00 AM. Signed by Judge Maria-Elena James on 3/20/2014. (cdnS, COURT STAFF) (Filed on 3/20/2014)

1 CRAIG B. SANDERS, SBN 284397

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COLLEEN BAL, SBN 167637
RIANA S. PFEFFERKORN, SBN 266817
WILSON SONSINI GOODRICH & ROSATI, P.C.
One Market, Spear Tower, Suite 3300
San Francisco, CA 94105-1126
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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BWP Media USA Inc.

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Facsimile: [phone]

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Garden City, NY 11530

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SANDERS LAW, PLLC

2 100 Garden City Plaza, Suite 500

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11 Attorneys for Defendant
ShopTap, Inc.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

16 BWP MEDIA USA INC. d/b/a PACIFIC )
COAST NEWS,

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Plaintiff,

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v.

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SHOPTAP, INC.,

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Defendant.

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CASE NO.: 3:13-cv-04990-MEJ
STIPULATION TO EXTEND TIME
TO RESPOND TO COMPLAINT
Complaint Filed: October 25, 2013

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WHEREAS, Plaintiff BWP Media USA Inc. d/b/a Pacific Coast News (“Plaintiff”) filed

25 the Complaint in this action on October 25, 2013 (Dkt. 1);
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WHEREAS, due to a miscommunication with Plaintiff’s process server regarding the

27 status of service on Defendant ShopTap, Inc. (“Defendant”), counsel for Plaintiff were under the
28 mistaken belief that service had not yet been effected, and mistakenly informed the Court in
CASE NO. 3:13-cv-04990-MEJ

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STIPULATION TO EXTEND TIME
TO RESPOND TO COMPLAINT

1 Plaintiff’s request for adjournment of the Initial Conference, dated January 8, 2014 (Dkt. 5), and
2 counsel for Defendant that service had not yet been effected, when in fact Plaintiff now believes
3 that Defendant had been served on January 7, 2014;
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WHEREAS, after resolving the miscommunication with their process server, Plaintiff’s

5 counsel filed a return of service with the Court on March 4, 2014 (Dkt. 7);
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WHEREAS, counsel for Defendant has requested from Plaintiff’s counsel additional time

7 in which to answer or otherwise respond to the Complaint, and Plaintiff’s counsel has agreed to
8 extend such time until April 17, 2014;
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WHEREAS, an initial Case Management Conference is currently set for March 27, 2014;
WHEREAS, additional time to prepare for the initial Case Management Conference

11 would greatly aid the parties’ ability to best present their respective positions and the status of
12 the case to the Court following Defendant’s answer or other response to the Complaint;
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IT IS HEREBY STIPULATED AND AGREED, by and among the undersigned, that

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1. pursuant to Civil Local Rule 6-1(a), Defendant’s deadline to answer or otherwise respond

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to the Complaint is extended to April 17, 2014, and
2. Plaintiff and Defendant respectfully request that the Court continue the initial Case
Management Conference to May 22, 2014.

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Respectfully submitted,

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SANDERS LAW, PLLC

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By: /s/ Craig B. Sanders
Craig B. Sanders

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Attorneys for Plaintiff
BWP Media USA, Inc. d/b/a Pacific Coast News

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25 Dated: March 20, 2014

WILSON SONSINI GOODRICH & ROSATI, P.C.

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By: /s/ Riana S. Pfefferkorn
Riana S. Pfefferkorn

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CASE NO. 3:13-cv-04990-MEJ

Attorneys for Defendant
ShopTap, Inc.
STIPULATION TO EXTEND TIME
-2TO RESPOND TO COMPLAINT

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4 IT IS SO ORDERED.
March 20, 2014

5 DATED: ___________________
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______________________________________
HON. MARIA-ELENA JAMES
United States Magistrate Judge

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CASE NO. 3:13-cv-04990-MEJ

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STIPULATION TO EXTEND TIME
TO RESPOND TO COMPLAINT

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CERTIFICATION
I, Craig B. Sanders, am the ECF User whose identification and password are being used

3 to file the Stipulation to Extend Time to Respond to Complaint. In compliance with Local
4 Rule 5-1(i)(3), I hereby attest that Riana S. Pfefferkorn has concurred in this filing.
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6 Dated: March 20, 2014

SANDERS LAW, PLLC

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By: /s/ Craig B. Sanders
Craig B. Sanders

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Attorneys for Plaintiffs
BWP Media USA, Inc. and
National Photo Group, LLC

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CASE NO. 3:13-cv-04990-MEJ

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STIPULATION TO EXTEND TIME
TO RESPOND TO COMPLAINT