Ennova Research SRL v. Beebell Inc.

Filing 34

STIPULATION AND ORDER re 33 STIPULATION WITH PROPOSED ORDER re 30 Order JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE SUBMISSION DEADLINE FOR DEFENDANT BEEBELL'S MOTION TO SET ASIDE ENTRY OF DEFAULT filed by Ennova Research SRL, Beebell Inc. Motions due by 3/3/2017. Signed by Magistrate Judge Kandis A. Westmore on 2/16/17. (sisS, COURT STAFF) (Filed on 2/16/2017)

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ROBERT J. YORIO (SBN 93178)
[e-mail]
JEFFREY M. CAPACCIO (SBN 129171)
[e-mail]
CARR & FERRELL LLP
120 Constitution Drive
Menlo Park, CA 94025
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
BEEBELL INC.

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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ENNOVA RESEARCH SRL, an Italian
corporation
Plaintiff,
v.

Civil Case No. 16-CV-05114-KAW
JOINT STIPULATION AND
[PROPOSED] ORDER TO CONTINUE
SUBMISSION DEADLINE FOR
DEFENDANT BEEBELL’S MOTION TO
SET ASIDE ENTRY OF DEFAULT

BEEBELL INC., a Delaware corporation, a
DOES 1 through 10, inclusive
Defendants.

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JOINT STIPULATION AND [PROPOSED] ORDER TO
CONTINUE SUBMISSION DEADLINE FOR DEFENDANT
BEEBELL INC.’S MOTION TO SET ASIDE ENTRY OF
DEFAULT

Civil Case No. 16-CV-05114-KAW

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WHEREAS:
A.

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Defendant Beebell Inc. requires additional time to retain alternate counsel in
place of Carr & Ferrell LLP;

B.

As a result of its need to retain alternate counsel, Defendant Beebell Inc. does not

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have sufficient time to prepare and file its Motion to Set Aside Entry of Default

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by Friday, February 17, 2017;

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C.

Counsel for their respective parties mutually agree to continue the submission

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deadline from February 17, 2017 until Friday, March 3, 2017 for filing

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Defendant’s Motion to Set Aside Entry of Default;

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D.

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There have been no previous time modifications in this case, either by stipulation
or Court Order; and

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E.

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DATED: February 15, 2017

This continuance will not affect any other Court deadline set in this case.

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CARR & FERRELL LLP

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By: /s/ Robert J. Yorio
ROBERT J.YORIO
JEFFREY M. CAPACCIO
[e-mail]
[e-mail]
120 Constitution Drive
Menlo Park, California 94025
Telephone: [phone]
Attorneys for Defendant, BEEBELL INC.

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MASSERAT LAW GROUP

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STIPULATED AND AGREED:

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By: _ /s/ Sassan Masserat_
Sassan J. Masserat
[e-mail]
468 N. Camden Drive, Suite 200
Beverly Hills, CA 90210
Tel. [phone]
Attorneys for Plaintiff, ENNOVA RESEARCH
SRL

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JOINT STIPULATION AND [PROPOSED] ORDER TO
CONTINUE SUBMISSION DEADLINE FOR DEFENDANT
BEEBELL INC.’S MOTION TO SET ASIDE ENTRY OF
DEFAULT

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PROPOSED ORDER

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NOW THEREFORE, IT IS HEREBY STIPULATED by and between the parties,
through their undersigned counsel, that the Defendant’s time within which to file a Motion to
Set Aside the Entry of Default is extended to March 3, 2017.
IT IS SO ORDERED.

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2/16
DATED: _______________, 2017

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__________________________________________________

KANDIS A. WESTMORE
United States Magistrate Judge

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE
HEARING DATE, OPPOSITION DATE, AND REPLY DATE
ON ALZA’S MOTION FOR SUMMARY JUDGMENT