Ronpak, Inc. v. Electronics For Imaging, Inc.

Filing 25

STIPULATION AND ORDER re 24 STIPULATION WITH PROPOSED ORDER for Request for Order Continuing Hearing Date for Defendant's Motion to Dismiss filed by Ronpak, Inc. Signed by Judge Jon S. Tigar on December 2, 2014. (wsn, COURT STAFF) (Filed on 12/2/2014)

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KENNETH E. KELLER (SBN 71450) [e-mail]
GARTH A. ROSENGREN (SBN 215732) [e-mail]
KELLER, SLOAN, ROMAN & HOLLAND LLP
555 Montgomery Street, 17th Floor
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Plaintiff RONPAK, INC.
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THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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RONPAK, INC., a New Jersey corporation
Plaintiff,

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vs.

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ELECTRONICS FOR IMAGING, INC., a
Delaware corporation,

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Defendant.

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Case No. 3:14-cv-04058 JST
STIPULATED REQUEST FOR ORDER
CONTINUING HEARING DATE FOR
DEFENDANT’S MOTION TO DISMISS
Current Hearing Date: December 4, 2014
Requested Hearing Date: January 8, 2015

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Pursuant to Local Rule 6-2, plaintiff Ronpak, Inc. and defendant Electronics for Imaging,
Inc., through their counsel of record, stipulate as follows:

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WHEREAS:

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1. On October 27, 2014, defendant filed a Motion to Dismiss. That motion is fully

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briefed and is presently set for hearing on December 4, 2014.

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2. The parties are actively engaged in settlement negotiations.

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3. The parties desire to continue the hearing date for defendant’s Motion to Dismiss, by

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at least thirty (30) days, in order to focus their efforts on settlement negotiations.

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4. The parties previously stipulated to one extension of time for defendant to respond to

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________________________________________________________________________________
STIPULATED REQUEST FOR ORDER CONTINUING HEARING DATE FOR
DEFENDANT’S MOTION TO DISMISS
CASE NO.: 3:14-cv-04058 JST

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the Complaint.
5. The parties do not anticipate that the requested continuance will impact any other date
currently set in this matter.
6. As required by Local Rule 6-2(a), plaintiff submits the Declaration of Kenneth E.
Keller in support of this stipulation.

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ACCORDINGLY, IT IS HEREBY STIPULATED AND AGREED, subject to Court
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approval, that the hearing on defendant’s Motion to Dismiss, currently set for December 4, 2014,
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shall be continued to January 8, 2015, or the next available hearing date.
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IT IS SO STIPULATED.

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Date: December 2, 2014

KERR & WAGSTAFFE LLP

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By: ___/s/ Frank Busch__________________
Frank Busch
Attorneys for Defendant
ELECTRONICS FOR IMAGING, INC.

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Date: December 2, 2014

KELLER, SLOAN, ROMAN & HOLLAND LLP

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By: ___/s/ Kenneth E. Keller________________
Kenneth E. Keller
Attorneys for Plaintiff RONPAK, INC.

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I hereby attest that I have been authorized by Frank Busch to execute on his behalf this
Stipulated Request for Order Continuing Hearing Date for Defendant’s Motion To Dismiss.

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Executed on this 2nd day of December, 2014 at San Francisco, California.

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______/s/ Kenneth E. Keller______
Kenneth E. Keller

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_________________________________________________________________________________
STIPULATED REQUEST FOR ORDER CONTINUING HEARING DATE
FOR DEFENDANT’S MOTION TO DISMISS
CASE NO.: 3:14-cv-04058 JST

ORDER

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Pursuant to stipulation, and good cause appearing, IT IS HEREBY ORDERED THAT the

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December 4, 2014 hearing on defendant’s Motion to Dismiss is hereby VACATED and shall be

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CONTINUED to January 8, 2015 at 2:00 p.m.

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ER

R NIA

. Ti ga r

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J u d ge J o

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RT

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NO

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THE HON. JON S. TIGAR
United States District Court Judge

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DERED
SO OR
IT IS
_______________________________________

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Dated: December __, 2014
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_________________________________________________________________________________
STIPULATED REQUEST FOR ORDER CONTINUING HEARING DATE
FOR DEFENDANT’S MOTION TO DISMISS
CASE NO.: 3:14-cv-04058 JST