Levi Strauss & Co. v. Blue in Green, LLC et al

Filing 23

ORDER granting 22 STIPULATION to Continue Case Management Conference and to Extend Time for Defendant to Respond to Complaint. Case Management Statement due by 3/28/2017. Case Management Conference continued to 4/4/2017 02:00 PM in Courtroom 2, 17th Floor, San Francisco. Signed by Judge William H. Orrick on 02/23/2017. (jmdS, COURT STAFF) (Filed on 2/23/2017)

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KILPATRICK TOWNSEND & STOCKTON LLP
GREGORY S. GILCHRIST (State Bar No. 111536)
GIA L. CINCONE (State Bar No. 141668)
RYAN BRICKER (State Bar No. 269100)
CALLA E. YEE (State Bar No. 306652)
Two Embarcadero Center, Suite 1900
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
E-Mail:
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiff
LEVI STRAUSS & CO.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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LEVI STRAUSS & CO.,

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Plaintiff,

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v.
BLUE IN GREEN, LLC, et al.,

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Case No. 3:16-cv-07011-WHO
STIPULATED REQUEST TO CONTINUE
CASE MANAGEMENT CONFERENCE,
STIPULATED REQUEST TO EXTEND
TIME FOR DEFENDANT TO RESPOND
TO COMPLAINT, AND [PROPOSED]
ORDER

Defendants.
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Complaint Filed: December 7, 2016
Trial Date:
Not Yet Set

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The undersigned attorneys for plaintiff Levi Strauss & Co. (“LS&Co.”) and defendant
Blue in Green, LLC (“Blue in Green”), stipulate as follows:

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LS&Co. filed its Complaint on December 7, 2016, and Blue in Green returned its

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waiver of service of summons on December 12, 2016. LS&Co. is currently attempting to serve

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the remaining defendants with the Complaint and related filings and papers pursuant to Article

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10(a) of the Hague Convention and Federal Rule of Civil Procedure 4(h)(2).

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/ / /
STIPULATED REQUEST TO CONTINUE CMC & EXTEND TIME FOR
DEFENDANT TO RESPOND TO COMPLAINT – Case No. 3:16-cv-07011-WHO

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In the meantime, LS&Co. and Blue in Green have discussed settlement, and believe that

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additional time before an initial case management conference would benefit those discussions.

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A case management conference is scheduled before the Court on March 7, 2017. In light of

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LS&Co.’s settlement discussions with Blue in Green, and its ongoing efforts to serve the

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remaining defendants, LS&Co. and Blue in Green respectfully request that the Court continue

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the case management conference for four (4) weeks, or until April 4, 2017, at 2:00 p.m. The

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requested extension will not affect the Court’s case management schedule.

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Blue in Green’s response to the Complaint was due on February 7, 2017, though
the parties have extended that deadline by stipulation until February 27, 2017. LS&Co. and

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Blue in Green now further agree to extend Blue in Green’s time to answer the complaint from

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February 27, 2017, until March 28, 2017. Blue in Green shall not use as a defense against any

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motion for contempt that LS&Co. stipulated to extend Blue in Green’s deadline to answer.

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Dated: February 23, 2017

KILPATRICK TOWNSEND & STOCKTON LLP

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By:

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/s/ Ryan Bricker
Ryan Bricker

Attorneys for Plaintiff
LEVI STRAUSS & CO.

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Dated: February 23, 2017

KAUFMAN & KAHN, LLP

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By:

/s/ Mark S. Kaufman
Mark S. Kaufman

Attorneys for Defendant
BLUE IN GREEN, LLC

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STIPULATED REQUEST TO CONTINUE CMC & EXTEND TIME FOR
DEFENDANT TO RESPOND TO COMPLAINT – Case No. 3:16-cv-07011-WHO

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ATTESTATION REGARDING SIGNATURES

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Pursuant to Local Rule No. 5-1(i)(3) regarding signatures, I attest under penalty of perjury

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that I have on file permission to sign for counsel indicated by a “conformed” signature within this

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e-filed document.

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/s/ Ryan Bricker
Ryan Bricker

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STIPULATED REQUEST TO CONTINUE CMC & EXTEND TIME FOR
DEFENDANT TO RESPOND TO COMPLAINT – Case No. 3:16-cv-07011-WHO

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ORDER

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Pursuant to stipulation, the case management conference scheduled for March 7, 2017,
is continued to April 4, 2017, at 2:00 p.m.
In addition, defendant Blue in Green’s time to answer the complaint is extended from
February 27, 2017, until March 28, 2017.
IT IS SO ORDERED.

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Dated: February 23, 2017

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William H. Orrick
United States District Judge

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69132711V.1

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STIPULATED REQUEST TO CONTINUE CMC & EXTEND TIME FOR
DEFENDANT TO RESPOND TO COMPLAINT – Case No. 3:16-cv-07011-WHO

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