FrontRow Calypso, LLC v. Front Row Education, Inc.

Filing 26

STIPULATION AND ORDER TO EXTEND DEADLINE re 25 . STIPULATION WITH PROPOSED ORDER filed by FrontRow Calypso, LLC, Front Row Education, Inc. Deadline to respond is 6/29/18. Signed by Judge Saundra Brown Armstrong on 5/30/18. (sisS, COURT STAFF) (Filed on 5/30/2018)

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NOEL M. COOK CBN 122777
OWEN, WICKERSHAM & ERICKSON, P.C.
455 Market Street, Suite 1910
San Francisco, California 94105
Telephone:
415.882.3200
Facsimile:
415.882.3232
Email: [e-mail]
Attorney for Defendant
FRONT ROW EDUCATION, INC.

Morgan E. Smith (SBN 293503)
FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER, LLP
[e-mail]
3300 Hillview Avenue
Palo Alto, CA 94304
Telephone:
[phone]
Facsimile:
[phone]
B. Brett Heavner (pro hac vice)
Sydney N. English (pro hac vice)
FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER, LLP
[e-mail]
[e-mail]
901 New York Avenue, N.W.
Washington, D.C. 20001-4413
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Plaintiff
FRONTROW CALYPSO, LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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FRONTROW CALYPSO, LLC,

Case No. 4:17-cv-05827-SBA

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Plaintiff,
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vs.

STIPULATION TO EXTEND DEADLINE
TO RESPOND TO COMPLAINT;
[PROPOSED] ORDER

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FRONT ROW EDUCATION, INC.,
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Defendant.
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In light of the parties’ ongoing settlement efforts, which are near completion, Plaintiff

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FrontRow Calypso, LLC (“FrontRow”) and Defendant Front Row Education, Inc. (“FRE”)

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respectfully request to amend the case schedule as detailed below.

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The Court granted the parties’ stipulation to amend the case schedule on April 27, 2018.

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(Dkt. 22.) FRE’s current deadline to answer or otherwise respond to the Complaint is May 29,

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2018. The parties have now signed a settlement agreement, with only a few steps remaining to be

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done. Therefore, in the interest of preserving judicial resources, and to allow the parties to focus
STIPULATION TO EXTEND DEADLINE; [PROPOSED] ORDER

Case No. 4:17-cv-05827-SBA

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their efforts on finishing the settlement process, FrontRow and FRE respectfully propose to

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extend FRE’s deadline to respond to the Complaint by 30 days, subject to the Court’s approval:

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Event
FRE’s deadline to answer or
otherwise respond to the Complaint

Current Deadline

Proposed New Deadline

May 29, 2018

June 29, 2018

The current case schedule has been previously modified by stipulation and Court order at

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Dkts. 20, 22 and 24. This case is still in its early stages. Discovery deadlines, motion deadlines,

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and trial have not yet been set. The requested time modification would thus not impact these

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deadlines.

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By signature below, counsel for Defendant attests that counsel for Plaintiff concurs in the

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filing of this paper.

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Dated: May 29, 2018

OWEN, WICKERSHAM & ERICKSON, P.C.

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By: /s/ Noel M. Cook
Noel M. Cook
Attorney for Defendant
FRONT ROW EDUCATION, INC.

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Dated: May 29, 2018

FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER, LLP

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By: /s/ Morgan E. Smith
Morgan E. Smith
Attorney for Plaintiff
FRONTROW CALYPSO, LLC

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[PROPOSED] ORDER
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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5/30/18
Dated:_______________

___________________________________
The Hon. Saundra B. Armstrong
United States District Judge
Northern District of California
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STIPULATION TO EXTEND DEADLINE; [PROPOSED] ORDER

Case No. 4:17-cv-05827-SBA