Conviva Inc. v. NicePeopleAtWork, S.L. et al

Filing 15

STIPULATION AND ORDER RESCHEDULING DATE OF CASE MANAGEMENT CONFERENCE 14 . Initial Case Management Conference reset for 8/23/2016 01:30 PM in Courtroom 4, 17th Floor, San Francisco. Signed by Judge Vince Chhabria on 6/8/2016. (afmS, COURT STAFF) (Filed on 6/8/2016)

1
2
3
4
5
6
7
8
9

Shane Brun (SBN 179079)
[e-mail]
Rachel M. Walsh (SBN 250568)
[e-mail]
GOODWIN PROCTER LLP
Three Embarcadero Center, 24th Floor
San Francisco, California 94111
Tel.: [phone]
Fax.: [phone]
Lana S. Shiferman (pro hac vice forthcoming)
[e-mail]
GOODWIN PROCTER LLP
53 State Street
Boston, Massachusetts 02109
Tel.: [phone]
Fax.: [phone]

10

Attorneys for CONVIVA, INC.

11

RICHARD G. FRENKEL (SBN 204133)
[e-mail]
LATHAM & ATKINS LLP
140 Scott Drive
Menlo Park, California 94025
Telephone: [phone]
Facsimile: 650.463.2600

12
13
14
15
16
17

Attorneys for Defendants
NICEPEOPLEATWORK, S.L., NPAW, Inc.,
FERRAN GUTIERREZ and SERGI VERGES

18

UNITED STATES DISTRICT COURT

19

NORTHERN DISTRICT OF CALIFORNIA

20

SAN FRANCISCO DIVISION

21
22

CONVIVA, INC.,

23
24
25
26
27

Case No. 3:16-cv-01543-VC
Plaintiff,

vs.
NICEPEOPLEATWORK, S.L., NPAW, Inc.,
FERRAN GUTIERREZ and SERGI VERGES
Defendants.

STIPULATION AND [PROPOSED]
ORDER TO RESCHEDULE DATE OF
CASE MANAGEMENT CONFERENCE
CMC Date:
Proposed CMC Date:
Time:
Courtroom:
Judge:

June 28, 2016
August 23, 2016
1:30 p.m.
4, 17th Floor
Hon. Vince Chhabria

28
STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE DATE OF CASE MANAGEMENT CONFERENCE
CASE NO. 3:16-cv-01543-VC

1

Pursuant to United States District Court, Northern District of California Local Rules 6-2

2

and 7-12, Plaintiff Conviva, Inc. (“Conviva”) and Defendants NicePeopleAtWork, S.L., NPAW,

3

Inc., Ferran Gutierrez, and Sergi Verges (collectively, “the NicePeopleAtWork Defendants”)

4

hereby file this Stipulation to reschedule the June 28, 2016 Case Management Conference to

5

August 23, 2016.

6
7

WHEREAS, on or about May 25, 2016, Defendants consented to waive service of a
summons in this action;

8

WHEREAS, no trial date has yet been set in this action;

9

WHEREAS, Defendants are currently required to respond to the Amended Complaint on

10
11
12

July 25, 2016. 
WHEREAS the Court scheduled a Case Management Conference for June 28, 2016 at
1:30 PM in Courtroom in Courtroom 4, 17th Floor, San Francisco (Dkt. No. 10);

13

WHEREAS the parties are in the process of discussing potential settlement;

14

WHEREAS the parties expressly agree that the NicePeopleAtWork Defendants do not

15

waive their rights to challenge the exercise of personal jurisdiction over the NicePeopleAtWork

16

Defendants, and do not waive their rights to challenge venue in this Court by entering into this

17

Stipulation;

18

NOW THEREFORE, the parties stipulate and jointly request that the Court reschedule

19

the Case Management Conference scheduled for June 28, 2016 at 1:30 PM to August 23, 2016 at

20

1:30 PM, and continue all other deadlines listed in Dkt. No. 4 accordingly.

21
22
23
24
25
26
27
28
1
STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE DATE OF CASE MANAGEMENT CONFERENCE
CASE NO. 3:16-cv-01543-VC

1

Dated: June 7, 2016

Respectfully submitted,

2

/s/ Shane Brun
Shane Brun
[e-mail]
GOODWIN PROCTER LLP
Three Embarcadero Center, 24th Floor
San Francisco, California 94111
Phone: [phone]
Fax: [phone]

3
4
5
6
7

Attorneys for Plaintiff CONVIVA, INC.

8
9
Dated: June 7, 2016

Respectfully submitted,

10
/s/ Richard G. Frenkel
Richard G. Frenkel
[e-mail]
LATHAM & WATKINS LLP
140 Scott Drive
Menlo Park, CA 94025
Phone: [phone]
Fax: [phone]

11
12
13
14
15

Attorneys for Defendants
NICEPEOPLEATWORK, S.L., NPAW, Inc.,
FERRAN GUTIERREZ and SERGI VERGES

16
17
18
19
20
21
22
23
24
25
26
27
28
2

STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE DATE OF CASE MANAGEMENT CONFERENCE
CASE NO. 3:16-cv-01543-VC

1
2

[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.

3
4
5

June 8, 2016
Dated: _____________

_________________________________________
THE HONORABLE VINCE CHHABRIA
United States District Court Judge

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
3
STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE DATE OF CASE MANAGEMENT CONFERENCE
CASE NO. 3:16-cv-01543-VC

CERTIFICATE OF SERVICE

1
2

I, Shane Brun, hereby certify that on June 7, 2016 a true copy of the foregoing

3

DECLARATION OF SHANE BRUN IN SUPPORT OF STIPULATION AND [PROPOSED]

4

ORDER TO RESCHEDULE DATE OF CASE MANAGEMENT CONFERENCE was served by

5

ECF upon all other counsel of record in this action.

6

June 7, 2016

/s/Shane Brun
Shane Brun

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

ACTIVE/85991906.1

3
DECLARATION OF SHANE BRUN IN SUPPORT OF STIPULATION AND [PROPOSED] ORDER TO
RESCHEDULE DATE OF CASE MANAGEMENT CONFERENCE