Rearden LLC et al v. Crystal Dynamics, Inc. et al

Filing 196

Order Extending Time by Judge Jon S. Tigar granting 195 Stipulation. (mllS, COURT STAFF) (Filed on 7/18/2019)

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RIMON, P.C.
Karineh Khachatourian (SBN 202634)
[e-mail]
Nikolaus A. Woloszczuk (SBN 286633)
[e-mail]
2479 E. Bayshore Road, Suite 210
Palo Alto, CA 94303
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants,
CRYSTAL DYNAMICS, INC. and SQUARE ENIX,
INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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REARDEN LLC, REARDEN MOVA LLC,
California limited liability companies,

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Plaintiffs,
v.

Case No. 17-cv-04187-JST
JOINT STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME

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CRYSTAL DYNAMICS, INC., a California
corporation, SQUARE ENIX, INC., a
Washington Corporation,
Defendants.

Judge: Hon. Jon S. Tigar

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JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING TIME; CASE NO. 17-CV-04187-JST

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Plaintiffs Rearden LLC and Rearden MOVA LLC (“Plaintiffs”) and Defendant Crystal
Dynamics, Inc., by and through their counsel of record, stipulate as follows:

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WHEREAS, on July 12, 2019, the Court entered an order granting in part and denying in
part Crystal Dynamics’s Renewed Motion for Summary Judgment (D.I. 194) (“MSJ Order”);

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WHEREAS, in the MSJ Order, the Court set certain deadlines for the parties to comply,
which will require coordination with affected third parties;

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WHEREAS, the Court previously ordered that once the MSJ Order issued, the parties

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would promptly contact the Court’s clerk and schedule a further case management conference (D.I.

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103);

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WHEREAS, the parties need additional time to digest the MSJ Order and meet and confer
on next steps; and
WHEREAS, counsel for both parties are scheduled to be out of the office collectively from
Wednesday, July 17, 2019 until Monday July 22, 2019.

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NOW THEREFORE, for good cause, the parties stipulate as follows:

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The parties shall meet and confer and complete the following by August 16, 2019 (1) submit

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to the Court, as noted in footnote 2 of the MSJ order, a stipulated proposed redacted version of the

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order or forego redaction altogether; and (2) present any agreements, disputes, or proposals to the

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Court concerning whether the incorporation by amendment of Rearden’s theory regarding the E3

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trailer, as set forth on pp. 12-13 of the MSJ Order, requires amendment of Rearden’s written

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complaint. The parties shall further contact the Court clerk to schedule a further case management

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conference once the issue of amendment is resolved. Any previously ordered deadlines are

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modified to the extent necessary to conform to the deadlines established in the previous sentence.

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IT IS SO STIPULATED, through Counsel of Record.

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DATED: July 16, 2019

RIMON, P.C.
By: /s/ Karineh Khachatourian__________
Karineh Khachatourian
Attorney for Crystal Dynamics

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JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING TIME; CASE NO. 17-CV-04187-JST

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DATED: July 16, 2019

HAGENS BERMAN SOBOL SHAPIRO LLP
By: /s/Mark S. Carlson__________________
Mark S. Carlson
Attorney for Plaintiffs

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JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING TIME; CASE NO. 17-CV-04187-JST

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Pursuant to the foregoing stipulation, IT IS SO ORDERED.

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DATED: ___________, 2019
July 18

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_________________________________
The Honorable Jon S. Tigar
United States District Judge

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JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING TIME; CASE NO. 17-CV-04187-JST

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CIVIL LOCAL RULE 5-1 ATTESTATION
I, Karineh Khachatourian, am the ECF user whose credentials were utilized in the electronic

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filing of this document. In accordance with Civil Local Rule 5-1(i)(3), I hereby attest that Mark

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Carlson concurred in the filing of this document.

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_/s/ Karineh Khachatourian____________
Karineh Khachatourian

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JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING TIME; CASE NO. 17-CV-04187-JST