Tendertouch v. Olababy

Filing 30

STIPULATION AND ORDER RE 29 TO EXTEND TIME TO FILE OPPOSITION AND REPLY BRIEFS AND CONTINUE HEARING ON PRELIMINARY INJUNCTION MOTION AND EXTEND TIME TO FILE CASE MANAGEMENT STATEMENT AND CONTINUE INITIAL CASE MANAGEMENT CONFERENCE. Initial Case Management Conference previously set for 6/29/2017 continued to 7/6/2017 at 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Signed by Judge Richard Seeborg on 6/22/17. (cl, COURT STAFF) (Filed on 6/22/2017) Modified on 6/22/2017 (cl, COURT STAFF).

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1 2 3 4 5 6 Salumeh R. Loesch, Pro Hac Vice salumeh.loesch@klarquist.com Derrick W. Toddy (S.B. #233174) derrick.toddy@klarquist.com KLARQUIST SPARKMAN, LLP 121 S.W. Salmon Street, Suite 1600 Portland, OR 97204 Telephone: (503) 595-5300 Facsimile: (503) 595-5301 Attorneys for Defendant OLALABABY INCORPORATED 7 8 9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 SAN FRANCISCO DIVISION 12 13 14 15 16 17 TENDERTOUCH, LLC., a California Corporation, Plaintiff, v. OLABABY INCORPORATED, an Oregon Corporation, Defendant. 18 JOINT STIPULATION TO (1) EXTEND TIME TO FILE OPPOSITION AND REPLY BRIEFS AND CONTINUE HEARING ON PRELIMINARY INJUNCTION MOTION AND (2) EXTEND TIME TO FILE CASE MANAGEMENT STATEMENT AND CONTINUE INITIAL CASE MANAGEMENT CONFERENCE; AND [PROPOSED] ORDER 19 20 21 22 23 24 25 26 27 28 Case No. 5:16-cv-06856-RS JOINT STIPULATION TO EXTEND TIME CASE NO. 5:16-cv-06856-RS Defendant Olababy Incorporated (“Olababy”) and Plaintiff Tendertouch, LLC 1 2 (“Tendertouch”) jointly stipulate, pursuant to Civil Local Rules 6-1(b), 6-2, and 7-12, to extend 3 the time to file any opposition and reply briefs regarding Tendertouch’s Motion for Preliminary 4 Injunction (“Motion for Preliminary Injunction”), to continue the hearing on the Motion for 5 Preliminary Injunction, to extend the time to file the Case Management Statement currently due 6 June 22, 2017, and to continue the Initial Case Management Conference currently set for June 7 29, 2017. WHEREAS, Olababy and Tendertouch hereby notify the Court that the parties have 8 9 reached an agreement in principle for dismissal of this matter with prejudice; Now therefore, the parties, through the undersigned counsel, hereby stipulate as follows: 10 • 11 that the deadline for filing an opposition to the Motion for Preliminary Injunction (ECF No. 28) be extended to June 28, 2017; 12 • 13 that the deadline for filing any reply to opposition to Motion for Preliminary Injunction be extended to July 5, 2017; 14 15 • that the hearing on the Motion for Preliminary Injunction be continued to July 27, 2017; 16 • that the deadline for Case Management Statement be extended to June 29, 2017; and 17 • that the Initial Case Management Conference be extended to July 6, 2017. The parties’ proposed time modification would not otherwise impact the schedule for this 18 19 case. 20 21 Dated June 21, 2017 Respectfully submitted, 22 23 KLARQUIST SPARKMAN, LLP DOWNS RACHLIN MARTIN PLLC 24 /s/Salumeh R. Loesch Salumeh R. Loesch (Pro Hac Vice) salumeh.loesch@klarquist.com Derrick W. Toddy (S.B. #233174) derrick.toddy@klarquist.com KLARQUIST SPARKMAN, LLP /s/Thomas D. Kohler Thomas D. Kohler (S.B. #207917) tkohler@drm.com DOWNS RACHLIN MARTIN PLLC 199 Main Street P.O. Box 190 Burlington, VT 05402-0190 25 26 27 28 JOINT STIPULATION TO EXTEND TIME CASE NO. 5:16-cv-06856-RS 1 1 2 Telephone: (802) 863-2375 Facsimile: (802) 862-7512 121 S.W. Salmon Street, Suite 1600 Portland, OR 97204 Telephone: (503) 595-5300 Facsimile: (503) 595-5301 Attorneys for Plaintiff TENDERTOUCH, LLC 3 4 Attorneys for Defendant OLALABABY INCORPORATED 5 6 7 8 9 Pursuant to Civil Local Rule 5-1(i), the filer attests that concurrence in the filing of this document has been obtained from the signatories above. /s/Salumeh R. Loesch 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JOINT STIPULATION TO EXTEND TIME CASE NO. 5:16-cv-06856-RS 2 1 [PROPOSED] ORDER PURSUANT TO THE FOREGOING STIPULATION OF THE PARTIES, IT IS 2 3 4 ORDERED THAT: 1. the deadline for any opposition to Tendertouch’s Motion for Preliminary Injunction be extended from June 21, 2017 to June 28, 2017; 5 6 2. the deadline for any reply to opposition to Motion for Preliminary Injunction be extended from June 28, 2017 to July 5, 2017; 7 8 3. the hearing on the Motion for Preliminary Injunction be continued from July 20, 2017 to July 27, 2017; 9 10 11 12 13 4. the deadline for the Case Management Statement be extended from June 22, 2017 to June 29, 2017; and 5. the Initial Case Management Conference be extended from June 29, 2017 to July 6, 2017. 14 15 16 6/21 Dated: __________________, 2017 The Honorable Richard Seeborg United States District Court Judge 17 18 19 20 21 22 23 24 25 26 27 28 JOINT STIPULATION TO EXTEND TIME CASE NO. 5:16-cv-06856-RS 1

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