Hydros Bottle LLC v. Stephen Gould Corporation

Filing 49

STIPULATION AND ORDER re 48 STIPULATION WITH PROPOSED ORDER (Joint Stipulation and Proposed Order for Extension of Plaintiff and Counter-Defendant Hydros's Time to File Motion for Attorney's Fees) filed by Hydros Bottle LLC. Signed by Judge Jon S. Tigar on April 17, 2017. (wsn, COURT STAFF) (Filed on 4/17/2017)

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1 2 3 4 5 6 7 8 9 10 THOMAS B. WATSON (SBN 181546) MCKOOL SMITH HENNIGAN, PC 300 S. Grand Avenue, Suite 2900 Los Angeles, CA 90071 Telephone: (213) 694-1200 Facsimile: (213) 694-1234 twatson@mckoolsmith.com Attorneys for Plaintiff and Counter-Defendant HYDROS BOTTLE LLC CHRISTOPHER T. HOLLAND (SBN 164053) HOLLAND LAW 220 Montgomery Street, Suite 800 San Francisco, CA 94104 Telephone: (415) 200-4981 cholland@hollandlawllp.com 11 12 13 14 15 BERNARD CHANIN (admitted pro hac vice) 2052 Cherry Street Philadelphia, PA 19103 Telephone: (215) 977-2396 bchanin.esq@gmail.com Attorneys for Defendant and Counter-Claimant STEPHEN GOULD CORPORATION 16 UNITED STATES DISTRICT COURT 17 NORTHERN DISTRICT OF CALIFORNIA 18 SAN FRANCISCO DIVISION 19 20 HYDROS BOTTLE LLC, a Delaware Limited Liability Company, 21 Plaintiff, 22 23 24 vs. STEPHEN GOULD CORPORATION, a New Jersey Corporation, Case No.: 3:16-cv-04077-JST JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF PLAINTIFF AND COUNTER-DEFENDANT HYDROS’S TIME TO FILE MOTION FOR ATTORNEY’S FEES 25 Defendant. 26 27 STIPULATION 28 Pursuant to Civil Local Rule 6-1, Plaintiff and Counter-Defendant Hydros Bottle LLC JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME CASE NO. 3:16-cv-04077-JST 1 (“Hydros”) and Defendant and Counterclaimant Stephen Gould Corporation (“SGC”) hereby 2 stipulate and agree as follows: WHEREAS, on April 3, 2017, the Clerk of the Court entered its Rule 68 Judgment in favor 3 4 of Hydros and against SGC; WHEREAS, pursuant to FRCP Rule 54 and Local Rule 54, Hydros and SGC have been 5 6 meeting and conferring to resolve the issue of the amount of attorney’s fees; WHEREAS, Hydros and SGC also have been meeting and conferring to resolve the amount 7 8 of prejudgment interest due to Hydros; WHEREAS, Hydros’s motion to determine the amount of attorney’s fees is due today, 9 10 April 17, 2017; WHEREAS, Hydros’s motion to determine the amount of prejudgment interest and thereby 11 12 to amend the judgment under FRCP Rule 59(e) to include that amount is due no later than May 1, 13 2017; 14 WHEREAS, the parties wish to have additional time to discuss the attorney’s fees and 15 prejudgment interest issues in an effort to resolve those matters without involving the Court, if 16 feasible; 17 18 19 WHEREAS, the parties agree that by entering into this stipulation, Hydros and SGC are not waiving any rights, claims, or defenses; and WHEREAS, there have been no previous time modifications Hydros’s time to move to 20 determine the amount of attorney’s fees due to Hydros and the change will not alter the date of any 21 event or any deadline already fixed by Court order. 22 //// 23 //// 24 //// 25 //// 26 //// 27 //// 28 //// 1 JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME CASE NO. 3:16-cv-04077-JST 1 THEREFORE, IT IS HEREBY STIPULATED, pursuant to Local Rules 6-2 and 54-5, by and 2 between the parties, and through their respective attorneys of record and subject to order of the 3 Court, that Hydros shall have up to and including May 1, 2017, the same day as its motion to 4 determine prejudgment interest is due, to move for a determination of the amount of attorney’s fees 5 to be awarded and/or otherwise move with respect to its request for attorney’s fees. 6 7 Dated: April 17, 2017 HOLLAND LAW 8 By: 9 10 /s/ Christopher T. Holland CHRISTOPHER T. HOLLAND Attorneys for Defendant and Counterclaimant STEPHEN GOULD CORPORATION 11 12 Dated: April 17, 2017 MCKOOL SMITH HENNIGAN, P.C. 13 By: 14 15 16 /s/ Thomas B. Watson THOMAS B. WATSON Attorneys for Plaintiff and Counter-Defendant HYDROS BOTTLE LLC 17 18 19 CIVIL L.R. 5-1(i) ATTESTATION I, Thomas B. Watson, hereby attest that I have been authorized by Christopher T. Holland, 20 counsel for Defendant and Counterclaimant Stephen Gould Corporation, to execute on his behalf this 21 Stipulation. 22 Dated: April 17, 2017 23 /s/ Thomas B. Watson Thomas B. Watson 24 25 26 27 28 2 JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME CASE NO. 3:16-cv-04077-JST [PROPOSED] ORDER 1 2 After consideration of the parties’ Stipulated Request for an Order for Extension of Plaintiff 3 and Counter-Defendant Hydros’s Time to File Motion for Attorney’s Fees, and good cause 4 appearing, 5 6 IT IS HEREBY ORDERED THAT: (1) Plaintiff and Counter-Defendant Hydros Bottle LLC shall have up to and including 7 May 1, 2017 to move for a determination of the amount of attorney’s fees to be awarded 8 and/or otherwise move with respect to its request for attorney’s fees. 9 10 IT IS SO ORDERED. 11 17 Dated: April ___, 2017 12 ___________________________________ HON. JON S. TIGAR UNITED STATES DISTRICT JUDGE 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME CASE NO. 3:16-cv-04077-JST

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