Intuitive Surgical, Inc. v. Illinois Union Insurance Company et al

Filing 20

STIPULATION AND ORDER re 19 STIPULATION WITH PROPOSED ORDER TO EXTEND TIME TO FILE OPPOSITION AND REPLY BRIEFS (DEFENDANT ILLINOIS UNION INSURANCE COMPANYS MOTION TO DISMISS COMPLAINT) filed by Intuitive Surgical, Inc. Signed by Judge Jon S. Tigar on December 23, 2015. (wsn, COURT STAFF) (Filed on 12/23/2015)

1 ALLEN RUBY (SBN 47109)
RAOUL D. KENNEDY (SBN 40892)
2 JAMES P. SCHAEFER (SBN 250417)
SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP
3 525 University Avenue, Suite 1400
Palo Alto, CA 94301
4 Telephone: [phone]
Facsimile: [phone]
5 [e-mail]
[e-mail]
6 [e-mail]
7 Attorneys for Plaintiff
INTUITIVE SURGICAL, INC.
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9

UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

12 INTUITIVE SURGICAL, INC.,
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CASE NO.: 3:15-cv-4834-JST

Plaintiff,
v.

15 ILLINOIS UNION INSURANCE
COMPANY, an Illinois corporation;
16 NAVIGATORS SPECIALTY INSURANCE
CO., a New York corporation,
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Defendants.
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JOINT STIPULATION TO EXTEND
TIME TO FILE OPPOSITION AND
REPLY BRIEFS (DEFENDANT
ILLINOIS UNION INSURANCE
COMPANY’S MOTION TO DISMISS
COMPLAINT); and
[PROPOSED] ORDER.
Hearing Date:
Time:
Courtroom:
Judge:

February 11, 2016
2:00 p.m.
9, 19th Floor
Hon. Jon S. Tigar

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JOINT STIP. TO EXTEND TIME RE: ILLINOIS UNION’S MTD

CASE NO. 3:15-CV-4834-JST

1

Plaintiff Intuitive Surgical, Inc. (“Intuitive”) and Defendant Illinois Union Insurance

2 Company (“Illinois Union”) jointly stipulate, pursuant to Civil Local Rules 6-1(b), 6-2, and 7-12,
3 to extend the time to file any opposition and reply briefs regarding Illinois Union’s Motion to
4 Dismiss Complaint (Dkt. 16) (the “Motion to Dismiss”).
5

WHEREAS, on December 21, 2015, Illinois Union filed its Motion to Dismiss and set the

6 motion for hearing on February 11, 2016;
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WHEREAS, as currently scheduled, Intuitive’s opposition to Illinois Union’s Motion to

8 Dismiss would be due January 4, 2016 and Illinois Union’s reply would be due January 11, 2016;
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WHEREAS, given the pending holidays, Intuitive requested a one-week extension to

10 respond to Illinois Union’s Motion to Dismiss, to which Illinois Union agreed;
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Now therefore, the parties, through the undersigned counsel, hereby stipulate as follows:

12

•

that the deadline for filing any opposition to Illinois Union’s Motion to Dismiss be

13 extended to January 11, 2016; and
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•

that the deadline for filing any reply in support of Illinois Union’s Motion to

15 Dismiss be extended to January 25, 2016.
16 DATED: December 22, 2015
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SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP

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By:

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/s/ James Schaefer
Attorneys for Plaintiff
INTUITIVE SURGICAL, INC.

COZEN O’CONNOR

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By:

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/s/ Charles Wheeler
Attorneys for Defendant
ILLINOIS UNION INSURANCE COMPANY

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Pursuant to Civil Local Rule 5-1(i), the filer attests that concurrence in the filing of this
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document has been obtained from the signatories above.
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/s/ James P. Schaefer
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JOINT STIP. TO EXTEND TIME RE: ILLINOIS UNION’S MTD

CASE NO. 3:15-CV-4834-JST

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[PROPOSED] ORDER
PURSUANT TO THE FOREGOING STIPULATION OF THE PARTIES, IT IS

3 ORDERED THAT:

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2. the deadline for filing any reply in support of Illinois Union’s Motion to Dismiss be
extended to January 25, 2016.

December 23
10 DATED: __________________, 2015

S

UNIT
ED

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RT
U
O

8 IT IS SO ORDERED.

S DISTRICT
TE
C
TA

ERED
O ORD
___________________________________
IT IS S

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NO

The Honorable Jon. S. Tigar
United States District .CourtaJudge
S Ti g r

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RT

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J u d ge J o

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A

H

ER

n

R NIA

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January 11, 2016; and

FO

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1. the deadline for filing any opposition to Illinois Union’s Motion to Dismiss be extended to

LI

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N

D IS T IC T
R

OF

C

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[PROPOSED] ORDER EXTENDING TIME RE: ILLINOIS UNION’S MTD
771308-LACSR02A - MSW

CASE NO. 3:15-CV-4834-JST