Caracal Enterprises LLC et al v. Robert Suranyi et al

Filing 29

STIPULATION AND ORDER 27 (1) EXTENDING TIME FOR DEFENDANT PASSPORTPARKING, INC. TO RESPOND TO THE FIRST AMENDED COMPLAINT AND (2) EXTENDING TIME FOR THE CASE MANAGEMENT CONFERENCE. Initial Case Management Conference previously set for 12/15/2016 Continued to 2/16/2017 at 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Case Management Statement due 2/9/2017. Signed by Judge Richard Seeborg on 11/30/16. (cl, COURT STAFF) (Filed on 11/30/2016)

1 IAN C. BALLON (SBN 141819)
[e-mail]
2 MONICA A. HERNANDEZ (SBN 280195)
[e-mail]
3 GREENBERG TRAURIG, LLP
1900 University Ave., 5th Floor
4 East Palo Alto, California 94303
Telephone: [phone]
5 Facsimile: [phone]
6 Attorneys for defendant,
PASSPORTPARKING, INC.
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

12 CARACAL ENTERPRISES LLC, and
CARACAL CONSULTING INC.,
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CASE NO. 3:16-CV-5073 (RS)

Plaintiffs,

STIPULATION AND [PROPOSED]
ORDER:

ROBERT SURANYI, ROBERT SURANYI
SYSTEMS SUPPORT, PASSPORT, INC.
17 and PASSPORTPARKING, INC.,

(1) EXTENDING TIME FOR
DEFENDANT
PASSPORTPARKING, INC. TO
RESPOND TO THE FIRST
AMENDED COMPLAINT AND

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v.
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Defendants.

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(2) EXTENDING TIME FOR THE
CASE MANAGEMENT
CONFERENCE

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Complaint Served: October 6, 2016

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STIPULATION TO EXTEND TIME FOR
PASSPORTPARKING, INC. TO RESPOND TO
INITIAL COMPLAINT

Case No. 3:16-CV-5073 (RS)

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Plaintiffs Caracal Enterprises LLC and Caracal Consulting Inc. (collectively “Plaintiffs”) and

2 defendant PassportParking, Inc. (“Passport”) hereby stipulate and agree that:
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1.

Plaintiffs and Passport are discussing the case and whether it can be resolved as between

4 them; and
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2.

Defendants Robert Suranyi and Robert Suranyi Systems Support were served using The

6 Hague Convention and have yet to enter an appearance beyond filing a stipulation extending their time
7 to respond to the complaint.
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3.

Accordingly, to avoid unnecessary expenditure of effort, and allow time for all parties to

9 appear, Plaintiffs have granted all defendants an additional 30-day extension of the deadline to answer or
10 otherwise respond to Plaintiffs’ First Amended Complaint. This is the second extension of time for
11 Passport and does not alter any deadlines already fixed by the Court.
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4.

For those same reasons, the Plaintiffs and Passport also agree, subject to court approval,

13 to extend the time for the Case Management Conference (“CMC) by sixty (60) days. The CMC is
14 currently scheduled for Thursday, December 15, 2016, and the parties agree to extend the CMC date
15 until Thursday, February 16, 2017 or as soon thereafter as is convenient for the court.
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17 DATED: November 29, 2016

GREENBERG TRAURIG, LLP

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By: /s/ Ian C. Ballon
Ian C. Ballon

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Attorneys for defendant
PASSPORTPARKING, INC.

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22 DATED: November 29, 2016

SMITH, GAMBRELL & RUSSELL, LLP

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By: /s/ Edward A. Pennington
Edward A. Pennington (admitted pro hac vice)
John P. Pennington (admitted pro hac vice)
Jennifer L. Feldman (admitted pro hac vice)
SMITH, GAMBRELL RUSSELL, LLP
1055 Thomas Jefferson Street, N.W.,
Suite 400
Washington, D.C. 20007
Tel: [phone]
Fax: [phone]

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STIPULATION TO EXTEND TIME FOR
PASSPORTPARKING, INC. TO RESPOND TO
INITIAL COMPLAINT

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Case No. 3:16-CV-5073 (RS)

[e-mail]
[e-mail]
[e-mail]

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Brian E. Mitchell (SBN 190095)
Marcel F. De Armas (SBN 289282)
MITCHELL + COMPANY
4 Embarcadero Center, Suite 1400
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for Plaintiffs
CARACAL ENTERPRISES LLC and
CARACAL CONSULTING INC.

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28 STIPULATION TO EXTEND TIME FOR
PASSPORTPARKING, INC. TO RESPOND TO
INITIAL COMPLAINT

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Case No. 3:16-CV-5073 (RS)

ATTESTATION CLAUSE

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2 I, Ian Ballon, am the ECF User whose ID and password are being used to file this STIPULATION
3 AND [PROPOSED] ORDER: (1) EXTENDING TIME FOR DEFENDANT PASSPORTPARKING,
4 INC. TO RESPOND TO THE FIRST AMENDED COMPLAINT AND (2) EXTENDING TIME FOR
5 THE CASE MAMAGEMENT CONFERENCE. In compliance with Civil L.R. 5-1(i), I hereby attest
6 that all signatories concurred in this filing.
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8 DATED: November 29, 2016

GREENBERG TRAURIG, LLP

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By: /s/ Ian C. Ballon
Ian C. Ballon

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Attorneys for defendant
PASSPORTPARKING, INC.

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28 STIPULATION TO EXTEND TIME FOR
PASSPORTPARKING, INC. TO RESPOND TO
INITIAL COMPLAINT

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Case No. 3:16-CV-5073 (RS)

[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED. The Case Management Conference is

3 rescheduled for February 16, 2017 at 10:00 a.m. The parties shall file a Joint Case Management
4 Statement at least one week prior to the Conference.
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6 Dated: November ____, 2016
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7
Richard Seeborg
United States District Judge

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28 STIPULATION TO EXTEND TIME FOR
PASSPORTPARKING, INC. TO RESPOND TO
INITIAL COMPLAINT

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Case No. 3:16-CV-5073 (RS)