Karl Storz Endoscopy-America, Inc. v. Stryker Corporation et al
Filing
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STIPULATION AND ORDER FOR FIRST EXTENSION OF TIME TO COMPLETE BRIEFING FOR PLAINTIFF'S MOTION TO STRIKE, AS MODIFIED BY THE COURT. Motion Hearing set for 7/10/2014 01:30 PM in Courtroom 3, 17th Floor, San Francisco before Hon. Richard Seeborg. Signed by Judge Richard Seeborg on 5/28/14. (cl, COURT STAFF) (Filed on 5/28/2014)
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Gregory J. Vogler (pro hac vice)
Email: gvogler@mcandrews-ip.com
Robert A. Surrette (pro hac vice)
Email: bsurrette@mcandrews-ip.com
Merle S. Elliott (pro hac vice)
Email: melliott@mcandrews-ip.com
Caroline A. Teichner (pro hac vice)
Email: cteichner@mcandrews-ip.com
McANDREWS, HELD & MALLOY, LTD.
500 West Madison Street, 34th Floor
Chicago, Illinois 60661
Telephone: (312) 775-8000
Facsimile: (312) 775-8100
William R. Overend (SBN 180209)
Email: woverend@reedsmith.com
REED SMITH LLP
101 Second Street, Suite 1800
San Francisco, California 94105-3659
Telephone: (415) 543-8700
Facsimile: (415) 391-8269
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 FIRST EXTENSION OF
TIME TO COMPLETE BRIEFING FOR
PLAINTIFF’S MOTION TO STRIKE, AS
MODIFIED BY THE COURT
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STIPULATION FOR EOT TO COMPLETE BRIEFING FOR PLAINTIFF’S MOTION
TO STRIKE
CASE NO. CV 14-00876 RS
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Pursuant to Civil Local Rules 6-2 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 undersigned counsel, hereby stipulate to and jointly request the
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Court as follows:
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1.
On May 16, 2014, KSEA served a Motion to Strike on Stryker and filed an
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accompanying Administrative Motion to File Documents Under Seal. (See Docket Nos. 46 and 45,
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respectively.)
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2.
KSEA’s Motion to Strike is noticed for hearing on June 26, 2014. (See Docket No.
45-3 at 1.)
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On May 20, 2014, Stryker filed a Declaration and Proposed Order in Support of
KSEA’s Administrative Motion to File Documents Under Seal. (Docket No. 47.)
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According to Civil Local Rule 7-3(a), Stryker’s Opposition to KSEA’s Motion to
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Strike is due on May 30, 2014. According to Civil Local Rule 7-3(c), KSEA’s Reply is due on June
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6, 2014.
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5.
Due to the intervening Memorial Day holiday and previously-planned travel, in order
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to allow the parties a full and fair opportunity to complete briefing on KSEA’s Motion to Strike, the
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parties each request a one-week extension of time to complete briefing relating to KSEA’s Motion to
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Strike. Specifically, Stryker requests until June 6, 2014, to respond to KSEA’s Motion to Strike and
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KSEA requests until June 20, 2014, to file a Reply in support of its Motion to Strike. These
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extensions will not change or alter any other deadlines currently set by the Court, including the
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noticed hearing date.
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6.
Accordingly, the parties hereby propose and stipulate to the following deadlines for
the completion of briefing relating to KSEA’s Motion to Strike:
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Stryker’s Opposition to KSEA’s
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Motion to Strike
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KSEA’s Reply in Support of its
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Motion to Stryker
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Hearing on KSEA’s Motion to Strike
June 6, 2014
June 20, 2014
June 26, 2014 (or at the convenience
STIPULATION FOR EOT TO COMPLETE BRIFING FOR PLAINTIFF’S MOTION
TO STRIKE
CASE NO. CV 14-00876 RS
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of the Court)
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7.
Pursuant to Civil Local Rule 6-2(a)(1)-(3), this stipulated request is accompanied by
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the Declaration of Merle S. Elliott setting forth (a) the reasons for the requested rescheduling; (b) all
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previous time modifications in the case; and (c) the effect of the requested rescheduling.
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Respectfully submitted,
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Dated: May 23, 2014
REED SMITH LLP
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/s/ William R. Overend1 _____________
William R. Overend
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Attorneys for Defendants,
STRYKER CORPORATION and
STRYKER COMMUNICATIONS, INC.
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Dated: May 23, 2014
BECK, BISMONTE & FINLEY, LLP
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/s/ Alfredo A. Bismonte _____________
Alfredo A. Bismonte
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Attorneys for Plaintiff,
KARL-STORZ ENDOSCOPY AMERICA,
INC.
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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 FOR EOT TO COMPLETE BRIFING FOR PLAINTIFF’S MOTION
TO STRIKE
CASE NO. CV 14-00876 RS
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ORDER
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PURSUANT TO STIPULATION, IT IS SO ORDERED. Plaintiff’s motion to strike shall be
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heard on July 10, 2014 at 1:30 p.m. in Courtroom 3 on the 17th Floor of the United States
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Courthouse, 450 Golden Gate Avenue, San Francisco
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DATED: May 28, 2014
RICHARD SEEBORG
United States District Judge
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STIPULATION FOR EOT TO COMPLETE BRIFING FOR PLAINTIFF’S MOTION
TO STRIKE
CASE NO. CV 14-00876 RS
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