Karl Storz Endoscopy-America, Inc. v. Stryker Corporation et al

Filing 108

STIPULATION AND ORDER FOR EXTENSION OF TIME TO FILE JOINT CLAIM CONSTRUCTION STATEMENT AND TO COMPLY WITH PATENT L.R. 4-3. Signed by Judge Richard Seeborg on 12/22/14. (cl, COURT STAFF) (Filed on 12/22/2014) Modified on 12/22/2014 (cl, COURT STAFF).

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Gregory J. Vogler (pro hac vice)
Email: [e-mail]
Robert A. Surrette (pro hac vice)
Email: [e-mail]
Merle S. Elliott (pro hac vice)
Email: [e-mail]
Caroline A. Teichner (pro hac vice)
Email: [e-mail]
McANDREWS, HELD & MALLOY, LTD.
500 West Madison Street, 34th Floor
Chicago, Illinois 60661
Telephone: [phone]
Facsimile: [phone]
William R. Overend (SBN 180209)
Email: [e-mail]
REED SMITH LLP
101 Second Street, Suite 1800
San Francisco, California 94105-3659
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants,
STRYKER CORPORATION and
STRYKER COMMUNICATIONS, INC.

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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KARL STORZ ENDOSCOPYAMERICA, INC.,
Plaintiff,

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v.
STRYKER CORPORATION and
STRYKER COMMUNICATIONS, INC.,
Defendants.

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Case No. CV 14-00876 RS

STIPULATION AND [PROPOSED]
ORDER FOR EXTENSION OF TIME TO
FILE JOINT CLAIM CONSTRUCTION
STATEMENT AND TO COMPLY WITH
PATENT L.R. 4-3

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STIPULATION AND [PROPOSED] ORDER FOR EOT TO FILE JOINT CLAIM
CONSTRUCTION STATEMENT AND TO COMPLY WITH PATENT L.R. 4-3
CASE NO. CV 14-00876 RS

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Pursuant to Civil Local Rules 6-1(b) and 7-12, Plaintiff Karl Storz Endoscopy-America, Inc.

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(“KSEA”) and Defendants Stryker Corporation and Stryker Communications, Inc. (collectively,

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“Stryker”), by and through their respective undersigned counsel, hereby stipulate to and jointly

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request an extension of time until January 12, 2015, to file their Joint Claim Construction Statement

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and to comply with Patent L.R. 4-3. The accompanying declaration of Merle S. Elliott sets forth all

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requirements of Civil Local Rule 6-2, including identifying all previous time modifications in the

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case. For the Court’s convenience, the Parties will not repeat all information contained in Ms.

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Elliott’s declaration, but the Parties do note as follows:

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1. The deadline for the Parties to file their Joint Claim Construction Statement and to

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comply with Patent L.R. 4-3 is currently set for Tuesday, January 6, 2015. (See Dkt. No. 59.) Given

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the upcoming winter holidays, and to allow the Parties a full and fair opportunity to review each

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other’s proposed claim constructions, meet and confer as necessary, and prepare the required

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documentation for the Court, the Parties jointly request a six (6) day extension of time, until January

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12, 2015, to file the Joint Claim Construction Statement and to comply with Patent L.R. 4-3.

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2. This stipulated extension will not alter any other deadlines currently set by the Court.

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3. Pursuant to Civil Local Rule 6-2(a), this stipulation is accompanied by the Declaration

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of Merle S. Elliott setting forth (1) the reasons for the requested enlargement of time; (2) all previous

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time modifications in this case; and (3) the effect of the requested enlargement of time.

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Respectfully submitted,

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Dated: December 22, 2014

REED SMITH LLP

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/s/ William R. Overend1 ____________
William R. Overend (SBN 180209)
Attorneys for Defendants,
STRYKER CORPORATION and
STRYKER COMMUNICATIONS, INC.

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1 In compliance with Civil Local Rule 5-1(i), I hereby attest that concurrence in the filing of this

document has been obtained from each of the other signatories hereto.
STIPULATION AND [PROPOSED] ORDER FOR EOT TO FILE JOINT CLAIM
CONSTRUCTION STATEMENT AND TO COMPLY WITH PATENT L.R. 4-3
CASE NO. CV 14-00876 RS

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Dated: December 22, 2014

BECK, BISMONTE & FINLEY, LLP

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/s/ Kimberly P. Zapata______________
Kimberly P. Zapata
Attorneys for Plaintiff,
KARL-STORZ ENDOSCOPY AMERICA, INC.

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STIPULATION AND [PROPOSED] ORDER FOR EOT TO FILE JOINT CLAIM
CONSTRUCTION STATEMENT AND TO COMPLY WITH PATENT L.R. 4-3
CASE NO. CV 14-00876 RS

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED:

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The Parties have until January 12, 2015, to file their Joint Claim Construction Statement
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and to comply with Patent L.R. 4-3.
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Dated: 12/22

, 2014

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Honorable Richard G. Seeborg
United States District Judge

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STIPULATION AND [PROPOSED] ORDER FOR EOT TO FILE JOINT CLAIM
CONSTRUCTION STATEMENT AND TO COMPLY WITH PATENT L.R. 4-3
CASE NO. CV 14-00876 RS

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