Hydros Bottle LLC v. Stephen Gould Corporation

Filing 17

STIPULATION AND ORDER re 16 STIPULATION WITH PROPOSED ORDER filed by Stephen Gould Corporation. Signed by Judge Jon S. Tigar on October 21, 2016. (wsn, COURT STAFF) (Filed on 10/21/2016)

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1 2 3 4 CHRISTOPHER T. HOLLAND (SBN 164053) KELLER, SLOAN, ROMAN & HOLLAND LLP 555 Montgomery Street, 17th Floor San Francisco, CA 94111 Telephone: (415) 249-8330 Facsimile: (415) 249-8333 cholland@ksrh.com 5 6 7 8 9 BERNARD CHANIN (pro hac vice pending) 2052 Cherry Street Philadelphia, PA 19103 Telephone: (215) 977-2396 bchanin.esq@gmail.com Attorneys for Defendant STEPHEN GOULD CORPORATION 10 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION 11 12 13 Case No.: 3:16-cv-04077-JST HYDROS BOTTLE LLC, a Delaware Limited Liability Company, 14 15 16 17 JOINT REQUEST AND STIPULATION FOR FURTHER EXTENSION OF TIME; [PROPOSED] ORDER Plaintiff, vs. STEPHEN GOULD CORPORATION, a New Jersey Corporation, 18 Defendant. 19 STIPULATION 20 21 Pursuant to Civil Local Rule 6-2, Plaintiff Hydros Bottle LLC (“Plaintiff”) and Defendant 22 Stephen Gould Corporation (“Defendant”) hereby stipulate and agree as follows, subject to approval 23 by the Court: 24 WHEREAS, Plaintiff filed its Complaint in this action on July 20, 2016 (D.I. 1); 25 WHEREAS, following a prior stipulation and an Order of the Court (D.I. 15), Defendant 26 currently has up to and including October 21, 2016 to answer, move, and/or otherwise respond to 27 Plaintiff’s Complaint; 28 WHEREAS, the parties have been engaging in discussions that would resolve and/or narrow 1 JOINT REQUEST AND STIPULATION FOR FURTHER EXTENSION OF TIME; [PROPOSED] ORDER CASE NO. 3:16-cv-04077-JST 1 certain portions of Plaintiff’s claims, and the Parties are close to finalizing those discussions; 2 WHEREAS, further, in the course of preparing to respond to Plaintiff’s Complaint, 3 Defendant has raised a legal issue with one of Plaintiff’s causes of action, an issue that Plaintiff is 4 presently evaluating; 5 WHEREAS, the parties anticipate filing a further stipulation shortly to address the foregoing 6 matters and that such a further stipulation would provide time for Plaintiff to amend its Complaint; 7 WHEREAS, the parties anticipate that an extension of approximately 10 days would allow 8 9 them sufficient time to address the foregoing matters; WHEREAS, the parties agree that by entering into this stipulation and/or requesting the 10 accompanying order, Defendant is not waiving any rights to move on the Complaint and/or 11 obligating itself to answer and/or otherwise respond to the Complaint in any particular way; and 12 WHEREAS, there have been one previous time modification in this case, but this further 13 modification is not made for purposes of delay, but rather as part of a continued good faith effort by 14 the parties to avoid or limit expenditure of Court resources where feasible. 15 THEREFORE, IT IS HEREBY STIPULATED by and between the parties, and through their 16 respective attorneys of record and subject to order of the Court, that Defendant shall have up to and 17 including November 1, 2016 to answer, move, and/or otherwise respond to Plaintiff’s Complaint; or 18 the Parties shall enter a further stipulation by that date. 19 KELLER, SLOAN, ROMAN & HOLLAND LLP Dated: October 20, 2016 20 By: 21 22 23 24 Dated: October 20, 2016 /s/ Christopher T. Holland CHRISTOPHER T. HOLLAND Attorneys for Defendant STEPHEN GOULD CORPORATION MCKOOL SMITH HENNIGAN, P.C. 25 By: 26 27 /s/ Thomas B. Watson THOMAS B. WATSON Attorneys for Plaintiff HYDROS BOTTLE LLC 28 2 JOINT REQUEST AND STIPULATION FOR FURTHER EXTENSION OF TIME; [PROPOSED] ORDER CASE NO. 3:16-cv-04077-JST CIVIL L.R. 5-1(i) ATTESTATION 1 2 I, Christopher T. Holland, hereby attest that I have been authorized by Thomas B. Watson, 3 counsel for Plaintiff Hydros Bottle LLC, to execute on his behalf this Stipulated Request for an 4 Order Extending Time to Answer, Move, and/or Otherwise Respond to Complaint and Continuing 5 Related Case Deadlines. 6 Dated: October 20, 2016 /s/ Christopher T. Holland Christopher T. Holland 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 JOINT REQUEST AND STIPULATION FOR FURTHER EXTENSION OF TIME; [PROPOSED] ORDER CASE NO. 3:16-cv-04077-JST [PROPOSED] ORDER 1 2 3 Under consideration of the parties’ Stipulated Request for an Order Extending Time to Answer, Move, and/or Otherwise Respond to Complaint, and good cause appearing, 4 IT IS HEREBY ORDERED THAT: 5 (1) 6 7 Defendant shall have up to and including November 1, 2016 to answer, move, and/or otherwise respond to Plaintiff’s Complaint. IT IS SO ORDERED. 8 Dated: October ____, 2016 21 9 10 ___________________________________ HON. JON S. TIGAR UNITED STATES DISTRICT JUDGE 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 JOINT REQUEST AND STIPULATION FOR FURTHER EXTENSION OF TIME; [PROPOSED] ORDER CASE NO. 3:16-cv-04077-JST

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