Dynatrace LLC v. Ramey et al

Filing 19

STIPULATION AND ORDER re 17 STIPULATION WITH PROPOSED ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE filed by Dynatrace LLC Case Management Statement due by 7/21/2016. Initial Case Management Conference set for 7/28/2016 09:30 AM in Courtroom 5, 17th Floor, San Francisco. Signed by Judge Edward M. Chen on 5/9/16. (bpfS, COURT STAFF) (Filed on 5/9/2016)

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DUANE MORRIS LLP
Karineh Khachatourian (CA SBN 202634)
[e-mail]
Daniel T. McCloskey (CA SBN 191944)
[e-mail]
Anjali Moorthy (CA SBN 299963)
[e-mail]
2745 Hanover Street
Palo Alto, CA 94304-1194
Telephone: [phone]
Facsimile: 650.847.4151
Attorneys for Plaintiff,
DYNATRACE LLC

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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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DYNATRACE LLC,
Plaintiff,
v.

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JAMES RAMEY, an individual, and
DEVICEBITS LLC, an Ohio limited
liability company,
Defendants.

Case No. 3:16-cv-01777-EMC
STIPULATION AND [PROPOSED]
ORDER CONTINUING INITIAL
CASE MANAGEMENT
CONFERENCE

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STIPULATION AND [PROPOSED] ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE;
CASE NO. 3:16-CV-01777-EMC

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DM2\6768328.1

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Pursuant to Civil L.R. 6-1 (b), Plaintiff Dynatrace LLC. (“Dynatrace”) and Defendants

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James Ramey and DeviceBits LLC (collectively, “Defendants”), by and through their undersigned

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attorneys, hereby state and stipulate, subject to Court approval, as follows:

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WHEREAS, on April 27, 2016, this Court issued an Order scheduling an initial Case

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Management Conference in this matter for July 21, 2016, at 9:30 a.m. and providing that the parties

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are to file a joint Case Management Conference Statement one week prior to the conference (see

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D.I. 13);

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WHEREAS, lead counsel for Dynatrace has pre-paid vacation travel to New York City
planned for July 21, 2016;

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WHEREAS, counsel for Dynatrace and Defendants have met and conferred and are

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amenable to continuing the Case Management Conference by one week, to July 28, 2016 (or, if the

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Court is not available on that date, to the next available date on the Court’s calendar), with the joint

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Case Management Conference Statement to be filed one week prior, on July 21, 2016;

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WHEREAS, there have been no previous time modifications, except that the Parties have

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stipulated to a 15 day extension of time for Defendants to answer or otherwise respond to the

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Complaint, to May 24, 2016, as set forth in a contemporaneous filing;

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WHEREAS, this requested continuance will have minimal to no impact on the case
management schedule, as no schedule has been adopted and no trial date has been set;
NOW THEREFORE, IT IS STIPULATED AND AGREED, subject to this Court’s

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approval, that the initial Case Management Conference in this matter shall be continued by one

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week, to July 28, 2016, at 9:30 a.m., in Courtroom 5, (or, if the Court is not available on that date,

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to the next available date on the Court’s calendar), and the joint Case Management Conference

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Statement shall be filed one week prior, on July 21, 2016.

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-1STIPULATION AND [PROPOSED] ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE;
CASE NO. 3:16-CV-01777-EMC
DM2\6768328.1

DUANE MORRIS LLP

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Dated: May 6, 2016

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GORDON REES, LLP
Dated: May 6, 2016

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Attorneys for Defendants,
JAMES RAMEY and DEVICEBITS LLC

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ATTESTATION

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the concurrence in the filing of this document has been obtained from its signatories.

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DUANE MORRIS LLP
Dated: May 6, 2016

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Attorneys for Plaintiff,
DYNATRACE LLC

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Having read and considered the foregoing Stipulation of the parties submitted herewith and
for good cause shown,

S DISTRICT
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PURSUANT TO STIPULATION, IT IS SO ORDERED:
C
TA

RT
U
O

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ORDER

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By: /s/ Karineh Khachatourian
Karineh Khachatourian
Daniel T. McCloskey
Anjali Moorthy

May 9, 2016
Dated:________________

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_______________________
ED
Hon. Edward M. Chen
ORDER
OJUDGE
UNITED STATES DISTRICT
IT IS S

RT

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en

d M. Ch

NO

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dwar
Judge E

H

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R NIA

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Pursuant to Civil L.R. 5-1(i)(3) regarding signatures, I attest under penalty of perjury that

FO

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By: /s/
Michael Pietrykowski

LI

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.

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By: /s/ Karineh Khachatourian
Karineh Khachatourian
Daniel T. McCloskey
Anjali Moorthy
Attorneys for Plaintiff,
DYNATRACE LLC

UNIT
ED

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C
OF
D IS T IC T
STIPULATION AND [PROPOSED] ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE;
R

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-2-

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CASE NO. 3:16-CV-01777-EMC

DM2\6768328.1