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

Filing 27

ORDER Granting 26 Stipulation EXTENDING TIME FOR DEFENDANTS TO RESPOND TO COMPLAINT AND ADJOURNING NOVEMBER 29, 2011 CASE MANAGEMENT CONFERENCE. Case Management Statement due by 1/11/2012. Case Management Conference set for 1/18/2012 02:00 PM. Signed by Judge Claudia Wilken on 11/28/2011. (ndr, COURT STAFF) (Filed on 11/28/2011)

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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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OAKLAND DIVISION

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CYPRESS SEMICONDUCTOR CORPORATION,
a Delaware Corporation,

(Case Assigned to Hon. Claudia Wilken)
Plaintiff,

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Case Number CV-11-617-CW

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

STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME FOR
DEFENDANTS TO RESPOND TO
COMPLAINT AND ADJOURNING
NOVEMBER 29, 2011 CASE
MANAGEMENT CONFERENCE

Defendants.

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Plaintiff and Defendants, by and through their respective undersigned counsel, stipulate and
agree as follows:

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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

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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

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September 23, 2011; and

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
TO RESPOND TO COMPLAINT AND ADJOURNING NOVEMBER 29, 2011 CASE MANAGEMENT
CONFERENCE - CV-11-617-CW

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WHEREAS, on September 29, 2011, the Court So Ordered the parties’ fourth stipulation

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extending the time for Defendants to respond to the Complaint in this action through and including

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October 24, 2011; and

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WHEREAS, on October 25, 2011, the Court So Ordered the parties’ fifth stipulation

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extending the time for Defendants to respond to the Complaint in this action through and including

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November 23, 2011; and

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WHEREAS the parties have now reached agreement on the terms of a settlement and
anticipate filing a stipulation of dismissal within fourteen (14) days; and
WHEREAS, accordingly, Defendants have met and conferred with Plaintiff and requested

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an additional 30-day extension of the time for all Defendants to move against, answer or respond

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to the Complaint (through and including December 23, 2011), by which time the parties anticipate

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having filed a stipulation of dismissal; and

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WHEREAS, Plaintiff has consented to Defendants’ request; and

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WHEREAS the Court had scheduled an initial Case Management Conference for

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November 29, 2011 at 2:00 p.m.; and
WHEREAS the parties believe that there will be no need for a Case Management
Conference because a stipulation of dismissal will be filed within fourteen (14) days;
IT IS HEREBY STIPULATED, by and between Plaintiff and Defendants, through their

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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 November 23, 2011 through and

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including December 23, 2011; and

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IT IS FURTHER STIPULATED that the Case Management Conference scheduled for
November 29, 2011 at 2:00 p.m. shall be adjourned.
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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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
TO RESPOND TO COMPLAINT AND ADJOURNING NOVEMBER 29, 2011 CASE MANAGEMENT
CONFERENCE - CV-11-617-CW

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DATED: November 22, 2011

Respectfully submitted,

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By

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/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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By

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/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 -

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Stephen L. Saxl (Not admitted in N.D. Cal.)
Toby S. Soli (Not admitted in N.D. Cal.)
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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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED. A case management conference will
be held on Wednesday, January 18, 2012, at 2:00 p.m.

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DATED:

November 28
________________, 2011

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The Honorable Claudia Wilken
United States District Judge

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
TO RESPOND TO COMPLAINT AND ADJOURNING NOVEMBER 29, 2011 CASE MANAGEMENT
CONFERENCE - CV-11-617-CW

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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

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MANAGEMENT CONFERENCE. In compliance with General Order 45, X.B., I hereby attest

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that Philip J. Wang has concurred in this filing.

TO

COMPLAINT

AND

ADJOURNING

NOVEMBER

29,

2011

CASE

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Date: November 23, 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
TO RESPOND TO COMPLAINT AND ADJOURNING NOVEMBER 29, 2011 CASE MANAGEMENT
CONFERENCE - CV-11-617-CW

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
TO RESPOND TO COMPLAINT AND ADJOURNING NOVEMBER 29, 2011 CASE MANAGEMENT
CONFERENCE - CV-11-617-CW

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