Nimbus Data Systems, Inc. v. Modus LLC

Filing 17

ORDER GRANTING JOINT STIPULATED REQUEST FOR CONTINUANCE AS MODIFIED 15 . Case Management Conference set for 2/4/2015 10:00 AM in Courtroom A, 15th Floor, San Francisco. Case Management Statement due by 1/28/2015. Signed by Judge Nathanael Cousins on 11/25/2014. (lmh, COURT STAFF) (Filed on 11/25/2014)

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GREGORY K. KLINGSPORN (203649)
NICOLAS A. FLEGEL (229360)
JENNIFER A. BREGANTE (294679)
JORGENSON, SIEGEL, McCLURE & FLEGEL, LLP
1100 Alma Street, Suite 210
Menlo Park, CA 94025
Telephone:
[phone]
Facsimile:
[phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Attorneys for Plaintiff
NIMBUS DATA SYSTEMS, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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NIMBUS DATA SYSTEMS, INC., a
California Corporation
Plaintiff,

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v.
MODUS LLC and DOES 1-10,

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Defendants.

Case No.: 3:14-cv-04192-NC
JOINT STIPULATED REQUEST FOR
CONTINUANCE OF INITIAL CASE
MANAGEMENT CONFERENCE; AND
[PROPOSED] ORDER AS MODIFIED
Dept.: Courtroom A - 15th Floor
Judge: Nathanael Cousins

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Pursuant to local Civil Rule 7-12, the parties to this action, Nimbus Data Systems, Inc.,

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and Modus LLC, hereby submit this joint stipulated request to continue the initial case

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management conference:

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currently scheduled for December 17, 2014, at 10:00 a.m. in Court A- 15th Floor;

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Per the Court’s Scheduling Order (Docket #4), the initial case management conference is

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Defendant Modus LLC has filed a motion to dismiss this matter (Docket #6,) challenging

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the jurisdiction and venue of the Northern District of California, which motion is pending

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and is set to be heard on December 3, 2014;

Jorgenson, Siegel, McClure & Flegel LLP
Attorneys at Law
Menlo Park, CA
[phone]

JOINT STIPULATED REQUEST
FOR CONTINUANCE OF CMC
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The parties have timely met and conferred regarding case management issues, as required
by the Court’s Scheduling Order; and

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The parties agree that it would be in the interest of judicial and party economy to extend

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the time for their obligation to comply with Rule 26’s initial disclosures and other

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discovery and case management matters to a time after the Court rules on its jurisdiction

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to hear this action.

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THEREFORE, the parties to this action stipulate and request that the initial case

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management conference, and related deadlines, be rescheduled by the Court to a time convenient

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to the Court but not less than thirty (30) days after the Court has issued an Order on the pending

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motion to dismiss.

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Dated: November 25, 2014

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JORGENSON, SIEGEL,
McCLURE & FLEGEL, LLP
By:

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Dated: November 25, 2014

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/s/ Gregory K Klingsporn
Gregory K. Klingsporn
Attorneys for Plaintiff
NIMBUS DATA SYSTEMS, INC.

LAW OFFICES OF BENJAMIN E.
MASKELL

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By:

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_______________________________
Hon. Nathanael M. Cousins ORDERED
SO

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IT IS
DIFIED
AS MO

NO
RT

JOINT STIPULATED REQUEST
FOR CONTINUANCE OF CMC

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Jorgenson, Siegel, McClure & Flegel LLP
Attorneys at Law
Menlo Park, CA
[phone]

thanael
Judge Na

ii

M. Cousi

R NIA

Dated: ______________
November 25, 2014

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RT
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ISTRIC
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The case management conference is
The Court hereby grants the stipulated request of the parties,. and will reschedule the
continued to February 4, 2015 at 10:00 a.m. Case management statement due January 28, 2015.
initial case management conference to a future date.

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ORDERED:

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GOOD CAUSE APPEARING, AND PURSUANT TO STIPULATION, IT IS

UNIT
ED

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/s/ Benjamin E. Maskell
Benjamin E. Maskell
Attorneys for Defendant
MODUS LLC

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