Argo Import Export, Ltd. v. Green Creative, LLC

Filing 24

STIPULATION AND ORDER RE 23 JOINT STIPULATION AND ORDER CONTINUING DEADLINE TO RESPOND TO COMPLAINT AND RE-SETTING INITIAL CASE MANAGEMENT CONFERENCE AS MODIFIED BY THE COURT. Case Management Statement due by 12/10/2020. Initial Case Manageme nt Conference previously set for 10/22/2020 has been continued to 12/17/2020 at 10:00 AM. All parties shall appear telephonically and must contact Court Conference at [phone] at least one week prior to the Conference to arrange their participation. Signed by Judge Richard Seeborg on 10/15/2020. (clS, COURT STAFF) (Filed on 10/15/2020)

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GOODIN, MACBRIDE,
SQUERI & DAY, LLP
Robert A. Goodin, Bar No. 061302
[e-mail]
Francine T. Radford, Bar No. 168269
[e-mail]
505 Sansome Street, Suite 900
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]

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SAN FRANCISCO

ATTORNEYS AT LAW

GOODIN, MACBRIDE, SQUERI & DAY, LLP

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Timothy R. Shannon (pro hac vice)
[e-mail]
Seth S. Coburn (pro hac vice)
[e-mail]
VERRILL DANA LLP
One Portland Square
Portland, ME 04101
Telephone
[phone]
Facsimile:
[phone]
Attorneys for Defendant
Green Creative, LLC

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO
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ARGO IMPORT EXPERT, LTD.,

Case No. 3:20-cv-04882 - RS

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Plaintiff,

JOINT STIPULATION AND ORDER
CONTINUING DEADLINE TO
RESPOND TO COMPLAINT AND
RE-SETTING INITIAL CASE
MANAGEMENT CONFERENCE
AS MODIFIED BY THE COURT

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v.
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GREEN CREATIVE, LLC,
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Defendant.
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CASE NO. 3:20-CV-04882 - RS

JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE TO RESPOND TO
COMPLAINT AND RE-SETTING INITIAL CASE MANAGEMENT CONFERENCE

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Plaintiff Argo Import Export, Ltd. (“Argo”) and defendant Green Creative, LLC, (“Green

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Creative”) hereby seek entry of the following Stipulation and Proposed Order concerning a 30-

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day continuation of Green Creative’s deadline for responding and a corresponding continuance of

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the initial case management conference.1 In support of their Stipulation and Proposed Order, the

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parties state as follows:

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On July 21, 2020, Argo filed the Complaint in the instant action alleging various Green
Creative tubed LED products infringe U.S. Pat. No. 10,677,397. ECF 1 (Complaint). On the

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same day, the Court generated an Order setting forth various early case management deadlines.

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ECF 7 (Initial Scheduling Order); see also ECF 12 (rescheduling). On October 7, 2020, Argo

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served the Complaint on Green Creative. ECF 17 (Return of Service).

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SAN FRANCISCO

ATTORNEYS AT LAW

GOODIN, MACBRIDE, SQUERI & DAY, LLP

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Under the current schedule, the parties must file their Rule 26(f) report on October 15,

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2020, ECF 12, yet Green Creative’s response to the complaint is not due until October 28, 2020.

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ECF 17. Further, lead counsel for Green Creative has a two-week trial in D.Mass. beginning on

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November 2, 2020. The parties therefore agree that a 30-day extension of the response to the

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complaint date to November 27, 2020 would be appropriate. The parties further agree that their

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Rule 26(f) Report should be due on or after Dec. 10, 2020 and the Court’s initial case management

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conference moved to December 17, 2020 at 10:00 am. All parties shall appear telephonically and

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must contact Court Conference at [phone] at least one week prior to the Conference to

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arrange their participation.

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Concurrence in this filing has been obtained from the other signatory.

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Green Creative has not yet responded or otherwise responded to the Complaint in this action. Without
waiving any defense concerning lack of personal jurisdiction or any other defense, Green Creative makes a
limited appearance for purposes of being heard on the instant Stipulation only.

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CASE NO. 3:20-CV-04882 - RS

JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE TO RESPOND TO
COMPLAINT AND RE-SETTING INITIAL CASE MANAGEMENT CONFERENCE

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INSIGHT, PLC
578 Washington Blvd # 503
Marina del Rey, CA 90292
Tel: [phone]
Fax: [phone]
[e-mail]

GOODIN, MACBRIDE,
SQUERI & DAY, LLP
505 Sansome Street, Suite 900
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]

By: /s/Steven Whitefield Ritcheson (by permission)

By: /s/ Francine T. Radford
Francine T. Radford

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Steven Whitefield Ritcheson

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SAN FRANCISCO

ATTORNEYS AT LAW

GOODIN, MACBRIDE, SQUERI & DAY, LLP

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HENINGER GARRISON DAVIS, LLC
James F. McDonough, III (GA Bar No. 507179)
Travis E. Lynch (GA Bar No. 162373)
3621 Vinings Slope, Suite 4320
Atlanta, GA 30339
Attorneys for Plaintiff
Argo Import Export, Ltd.
Dated: October 15, 2020

VERRILL DANA LLP
Timothy R. Shannon (pro hac vice)
Seth S. Coburn (pro hac vice)
One Portland Square
Portland, ME 04101
Attorneys for Defendant
Green Creative, LLC

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SO ORDERED.
Dated: 10/15/2020

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By: Hon. Richard Seeborg
United States District Judge

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3845/001/X220306.v1

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CASE NO. 3:20-CV-04882 - RS

JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE TO RESPOND TO
COMPLAINT AND RE-SETTING INITIAL CASE MANAGEMENT CONFERENCE
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