AllCells, LLC v. Jack Zhai et al

Filing 118

STIPULATION AND ORDER re 117 re Extension of Time for Answer filed by AllCells, LLC. Signed by Judge Edward M. Chen on 4/11/17. (bpfS, COURT STAFF) (Filed on 4/11/2017)

Lily Lim (SBN 214536)
[e-mail]
Michael Liu Su (SBN 300590)
[e-mail]
FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER, LLP
3300 Hillview Avenue
Palo Alto, CA 94304-1280
Telephone:
[phone]
Facsimile:
[phone]

J. James Li (SBN 202855)
1 Tony Abdollahi (SBN 157235)
LILAW, INC.
2 5050 El Camino Real, Suite 200
Los Altos, California 94022
3 Telephone: [phone]
Facsimile: [phone]
4 Email: [e-mail]
5 Attorneys for Plaintiff
AllCells, LLC.
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Attorneys for Defendant
Cepheus Biosciences, Inc.

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Mark S. Zhai (SBN 287988)
[e-mail]
7660 Beverly Blvd. Apt. 307
Los Angeles, CA 90036-2734
Telephone:
[phone]
Facsimile:
[phone]

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Attorney for Defendants
Jack Zhai and James Lee

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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16 ALLCELLS, LLC, a California Limited
Liability Company
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Plaintiff,
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v.
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20 JACK ZHAI, an individual, JAMES LEE, an
individual, and CEPHEUS BIOSCIENCES,
21 INC., a Delaware Company

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JOINT STIPULATED REQUEST AND
PROPOSED ORDER FOR AN
EXTENSION OF TIME FOR
DEFENDANTS TO RESPOND TO
COMPLAINT PURSUANT TO CIVIL
LOCAL RULE 6-2

Defendants.

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Case No.: 3:16-cv-7323-EMC

Defendants Jack Zhai, James Lee, and Cepheus Biosciences, Inc. (collectively
“Defendants”) and Plaintiff AllCells, LLC (“Plaintiff”), through their undersigned attorneys,
hereby stipulate and, pursuant to Local Rule 6-2, jointly request an order from the Court for an
extension of time for Defendants to file their Answer and Counterclaims from April 10, 2017 to
April 24, 2017.

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JOINT STIPULATED REQUEST FOR AN EXTENSION OF
TIME FOR DEFENDANTS TO FILE ANSWER AND COUNTERCLAIMS
CASE NO.: 3:16-cv-7323

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JOINT DECLARATION OF THE PARTIES:

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WHEREAS, Defendants’ Answer and Counterclaims are due on April 10, 2017, 10 days

3 after the Court’s Order (D.I. 102) on Defendants’ Motion to Dismiss,
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WHEREAS, the parties are currently pursuing settlement discussions and mutually agree

5 that an extension of the deadline for Defendants to file their Answer and Counterclaims to April
6 24, 2017 is necessary to continue having productive settlement discussions,
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WHEREAS, the parties agree that the requested time modification would have no effect

8 on the other deadlines and schedule for the case,
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THEREFORE, it is hereby STIPULATED that upon the Court’s order pursuant to Civil

10 Local Rule 6-2, the deadline for Defendants to file their Answer and Counterclaims is extended
11 to and including April 24, 2017.
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Dated: April 10, 2017

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FINNEGAN, HENDERSON, FARABOW,
GARRETT, DUNNER, LLP,
By:

/s/ Lily Lim
Lily Lim
Attorneys for Defendant
CEPHEUS BIOSCIENCES, INC.

By:

/s/ Mark S. Zhai
Mark S. Zhai
Attorney for Defendants
JACK ZHAI AND JAMES LEE

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Dated: April 10, 2017

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Dated: April 10, 2017

LILAW, INC.
By:

/s/ J. James Li
J. James Li
Attorney for Plaintiff
ALLCELLS, LLC

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JOINT STIPULATED REQUEST FOR AN EXTENSION OF
TIME FOR DEFENDANTS TO FILE ANSWER AND COUNTERCLAIMS
CASE NO.: 3:16-cv-7323

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Having considered the foregoing joint stipulated request, and finding that good cause

2 exists for an extension of the deadline for Defendants to file their Answer and Counterclaims to
3 April 24, 2017,

NO

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Judge E

Attestation re Electronic Signatures
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Chen

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By: ____________________________________
HON. EDWARD M.D
CHEN
RE
UnitedO ORDE
States District Judge
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PURSUANT TO THE JOINT STIPULATION, IT IS SO ORDERED.
April 11
S DISTRICT
Dated: _________, 2017
TE

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C
F
D IS T IC T O
R
I, J. James Li, attest pursuant to Northern District Local Rule 5-1(i)(3) that all other
RN

13 signatories to this document, on whose behalf this filling is submitted, concur in the filing’s
14 content and have authorized this filing.
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Dated: April 10, 2017
By:

/s/ J. James Li
J. James Li
Attorney for Plaintiff

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JOINT STIPULATED REQUEST FOR AN EXTENSION OF
TIME FOR DEFENDANTS TO FILE ANSWER AND COUNTERCLAIMS
CASE NO.: 3:16-cv-7323