Cypress Semiconductor Corporation v. Deutsche Bank Securities, Inc. et al

Filing 22

ORDER Granting 20 Stipulation Extending Time for Defendants to Respond to Complaint. Signed by Judge Claudia Wilken on 9/29/2011. (ndr, COURT STAFF) (Filed on 9/29/2011)

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William J. Goines (SBN 61290)
GREENBERG TRAURIG, LLP
1900 University Avenue, 5th Floor
East Palo Alto, CA 94303
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendants
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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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CYPRESS SEMICONDUCTOR CORPORATION,
a Delaware Corporation,
Plaintiff,

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CW
Case Number CV-11-617-JF
STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME FOR
DEFENDANTS TO RESPOND TO
COMPLAINT

v.
DEUTSCHE BANK SECURITIES INC., a
Delaware Corporation, DEUTSCHE BANK ALEX.
BROWN, a Division of Deutsche Bank Securities
Inc., and DEUTSCHE BANK AG,

Honorable Jeremy Fogel

Defendants.

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Plaintiff and Defendants, by and through their respective undersigned counsel, stipulate and
agree as follows:
WHEREAS, on June 2, 2011, the Court So Ordered the parties’ initial stipulation

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extending the time for Defendants to respond to the Complaint in this action to July 11, 2011; and

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WHEREAS, on July 8, 2011, the Court So Ordered the parties’ second stipulation

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extending the time for Defendants to respond to the Complaint in this action through and including
August 24, 2011; and

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WHEREAS, on September 1, 2011, the Court So Ordered the parties’ third stipulation
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extending the time for Defendants to respond to the Complaint in this action through and including
STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
CW
TO RESPOND TO COMPLAINT - CV-11-617-JF

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September 23, 2011;
WHEREAS the parties have been discussing and are continuing to discuss the possible
resolution of this dispute and believe that an additional thirty (30) days would permit them to
resolve this dispute; and

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WHEREAS, accordingly, Defendants have met and conferred with Plaintiff and requested
an additional 30-day extension of the time for all Defendants to move against, answer or respond
to the Complaint (through and including October 24, 2011); and
WHEREAS, Plaintiff has consented to Defendants’ request;
IT IS HEREBY STIPULATED, by and between Plaintiff and Defendants, through their
respective counsel, and subject to Court approval, that the time for all Defendants to move against,

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answer or respond to the Complaint shall be extended from September 23, 2011 through and
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including October 24, 2011.
In accordance with General Order 45 of the United States District Court for the Northern

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District of California, I attest that concurrence in the filing of this document has been obtained

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from the undersigned counsel.

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DATED: September 22, 2011

Respectfully submitted,

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By

/s/ Philip J. Wang
Philip J. Wang (SBN 218349)
Justin S. Chang (SBN 205925)
WANG & CHANG, A PROFESSIONAL
LAW CORPORATION
One Maritime Plaza, Suite 825
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for Plaintiff

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
CW
TO RESPOND TO COMPLAINT - CV-11-617-JF

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By

/s/ William J. Goines
William J. Goines (SBN 61290)
GREENBERG TRAURIG, LLP
1900 University Avenue, 5th Floor
East Palo Alto, CA 94303
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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- and Stephen L. Saxl (Pro Hac Vice Motion
To Be Filed)
Toby S. Soli (Pro Hac Vice Motion
To Be Filed)
GREENBERG TRAURIG, LLP
200 Park Avenue
New York, New York 10166
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for Defendants

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ATTESTATION CLAUSE

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I, William J. Goines, am the ECF User whose ID and password are being used to file this

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS TO

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RESPOND TO COMPLAINT. In compliance with General Order 45, X.B., I hereby attest that

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Philip J. Wang has concurred in this filing.

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Date: September 22, 2011

GREENBERG TRAURIG, LLP

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By: /s/ William J. Goines

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
CW
TO RESPOND TO COMPLAINT - CV-11-617-JF

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

DATED:

Sept. 29
___________, 2011
The Honorable Jeremy
Honorable Claudia Wilken Fogel
United United DistrictDistrict Judge
States States Judge

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
CW
TO RESPOND TO COMPLAINT - CV-11-617-JF

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