Products and Ventures International v. Axus Stationary (Shanghai) Ltd. et al

Filing 31

ORDER GRANTING re 30 Stipulation for Extension of Time to Respond to Complaint, filed by Andre Viegas, Axus Stationary (Hong Kong) Ltd., Highton Ltd., Kenpark Ltd., Roberta Trading Corporation. Signed by Chief Magistrate Judge Joseph C. Spero on 3/22/16. (klhS, COURT STAFF) (Filed on 3/22/2016)

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1 2 3 4 5 6 7 8 9 10 11 12 Randolph Gaw Gaw Poe LLP Embarcadero 4, Suite 1400 San Francisco, California 94111 Telephone: 415.734.3308 Facsimile: 415.737.0642 rgaw@gawpoe.com Attorneys for Plaintiff PRODUCTS AND VENTURES INTERNATIONAL Mark C. Goodman (Bar No. 154692) HOGAN LOVELLS US LLP 3 Embarcadero Center, 15th Floor San Francisco, California 94111 Telephone: 415.374.2300 Facsimile: 415.374.2499 mark.goodman@hoganlovells.com Attorneys Specially Appearing for Defendants AXUS STATIONARY (HONG KONG) LTD., ANDRE VIEGAS, HIGHTON LTD., ROBERTA TRADING CORPORATION and KENPARK LTD 13 14 UNITED STATES DISTRICT COURT 15 NORTHERN DISTRICT OF CALIFORNIA 16 17 PRODUCTS AND VENTURES INTERNATIONAL, Plaintiff, 18 19 20 21 22 23 24 25 v. Case No.: 3:16-CV-669 STIPULATION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT [SPECIAL APPEARANCE] AXUS STATIONARY (SHANGHAI) LTD., AXUS STATIONARY (HONG KONG) LTD., SHANGHAI MARCO STATIONARY CO. LTD., SHANGHAI LAIKESHENG PEN MATERIAL CO. LTD. d/b/a/ SHANGHAI LEXON, PEIFENG XU, ANDRE VIEGAS, HIGHTON LTD., ROBERTA TRADING CORPORATION, and KENPARK LTD. Defendants. 26 27 28 STIPULATION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT – CASE NO. 3:16-CV-669 1 Defendants Axus Stationary (Hong Kong) Ltd., Andre Viegas, Highton Ltd., Roberta 2 Trading Corporation and Kenpark Ltd. (collectively, “the Defendants”) hereby specially appear in 3 the above-captioned case for the limited purpose of filing this Stipulation for Extension of Time 4 to Respond to Complaint. The Defendants’ special and limited appearance is not intended, and 5 shall not be construed, as a waiver of any of the Defendants’ rights to challenge the jurisdiction of 6 this Court or the sufficiency of service in this matter. 7 8 The Defendants and plaintiff Products and Ventures International have met and conferred and state the following: 9 Whereas, the Defendants have requested an extension of time for the Defendants to 10 respond to the complaint in the above-captioned action and the plaintiff is willing to 11 accommodate that request; 12 Therefore, pursuant to Civil Local Rule 6-1(a), the plaintiff and the Defendants, by and 13 through their respective counsel, hereby stipulate and agree that the Defendants shall have an 14 extension of time up to and including April 18, 2016 in which to respond to the complaint in this 15 action. 16 17 IT IS SO STIPULATED. GAW POE LLP Dated: March 21, 2016 18 19 By: /s/ Randolph Gaw Randolph Gaw Attorneys for Plaintiff PRODUCTS AND VENTURES INTERNATIONAL 20 21 ER R NIA Spero H 28 Judge Jo RT 27 seph C. NO 26 D RDERE OO IT IS S LI 25 Dated: 3/22/16 UNIT ED 24 RT U O S 23 HOGAN LOVELLS US LLP ISTRIC ES D TC AT T FO Dated: March 21, 2016 A 22 N F D IS T IC T O R C By: /s/ Mark C. Goodman Mark C. Goodman Attorneys Specially Appearing for Defendants AXUS STATIONARY (HONG KONG) LTD., ANDRE VIEGAS, HIGHTON LTD., ROBERTA TRADING CORPORATION and KENPARK LTD -1- STIPULATION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT – CASE NO. 3:16-CV-669

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