Pace Anti-Piracy, Inc. v. Inside Secure et al

Filing 39

ORDER by Judge Haywood S. Gilliam, Jr. Granting 38 Stipulation to Modify Briefing Schedule for Defendants' 37 Motion to Dismiss Complaint. (ndrS, COURT STAFF) (Filed on 1/3/2018)

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John V. Picone III, Esq. (State Bar No. 187226)
[e-mail]
Jennifer S. Coleman, Esq. (State Bar No. 213210)
[e-mail]
C. Gideon Korrell (State Bar No. 284890)
[e-mail]
HOPKINS & CARLEY
A Law Corporation
The Letitia Building
70 South First Street
San Jose, California 95113-2406
mailing address:
P.O. Box 1469
San Jose, CA 95109-1469
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiff
PACE Anti-Piracy, Inc.

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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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PACE ANTI-PIRACY, INC. a California
corporation,

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Plaintiff,
v.

CASE NO. 4:17-cv-05860-HSG
STIPULATION AND ORDER TO
MODIFY BRIEFING SCHEDULE FOR
DEFENDANTS’ MOTION TO DISMISS
COMPLAINT

INSIDE SECURE, a French legal entity, and
INSIDE SECURE CORP., a Delaware
corporation,

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Defendant.

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H OPKINS & C ARLEY
ATTORNEYS AT LAW
SAN JOSE

PALO ALTO

-1626\2876780.1

STIPULATION AND ORDER TO MODIFY BRIEFING SCHEDULE FOR DEFENDANTS’ MOTION TO DISMISS
COMPLAINT
CASE NO. 4:17-CV-05860-HSG

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STIPULATION

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This Stipulation is made pursuant to Local Rule 6-2 by and between Plaintiff PACE Anti-

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Piracy, Inc. (“PACE”) and Defendants Inside Secure and Inside Secure Corp. (collectively,

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“Defendants”) through their respective attorneys. PACE and Defendants (collectively, the

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“Parties”) stipulate as follows:

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1.

Defendants filed their Motion to Dismiss Complaint Pursuant to Federal Rule of

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Civil Procedure 12(b)(6) on December 26, 2017 (“Motion to Dismiss”). The Motion to Dismiss is

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currently scheduled for hearing on March 22, 2018 at 2:00 p.m. (Dkt. No. 37).

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2.

Based on the filing date, the opposition to the Motion to Dismiss is due to be filed by

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January 9, 2018, and the reply in support of the Motion to Dismiss is due to be filed on January 16,

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2018.

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3.

Given the intervening Holiday, the Parties request a modification to the briefing

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schedule for the Motion to Dismiss by one week. The requested modification to the briefing

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schedule would not have an effect on the remaining schedule for the case.

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4.

There have been three previous requests for time modifications: i) two extensions

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of time for Defendants to respond to PACE’s Complaint (Dkt. Nos. 20 and 31); and ii) a

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continuance of the Initial Case Management Conference (Dkt. No. 33).

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5.

The Parties have agreed to modify the Motion to Dismiss briefing schedule as

follows:

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Pleading

Current Deadline

Stipulated Revised Deadline

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Opposition to Motion to
Dismiss

January 9, 2018

January 16, 2018

Reply in support of Motion to
Dismiss

January 16, 2018

January 23, 2018

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H OPKINS & C ARLEY
ATTORNEYS AT LAW
SAN JOSE

PALO ALTO

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
-2626\2876780.1

STIPULATION AND ORDER TO MODIFY BRIEFING SCHEDULE FOR DEFENDANTS’ MOTION TO DISMISS
COMPLAINT
CASE NO. 4:17-CV-05860-HSG

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Dated: January 3, 2018

HOPKINS & CARLEY, A Law Corporation

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By: /s/ John Picone
John V. Picone III
Attorney for Plaintiff PACE Anti-Piracy, Inc.

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Dated: January 3, 2018
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SKADDEN, ARPS, SLATE, MEAGHER & FLOM
LLP
By: /s/ James Pak
James Y. Pak
Attorney for Defendants Inside Secure and
Inside Secure Corp.

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ATTESTATION OF E-FILED SIGNATURE

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Pursuant to Local Rule 5-1(i)(3), I hereby certify that I have obtained the concurrence in the
filing of this document from all signatories for whom a signature is indicated by a “conformed”
signature (/ s /) within this electronically filed document and I have on file records to support this
concurrence for subsequent production to the Court if so ordered or for inspection upon request.

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Dated: January 3, 2018

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By: /s/ John Picone
John V. Picone III
Attorney for Plaintiff
PACE Anti-Piracy, Inc.

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H OPKINS & C ARLEY
ATTORNEYS AT LAW
SAN JOSE

PALO ALTO

-3626\2876780.1

STIPULATION AND ORDER TO MODIFY BRIEFING SCHEDULE FOR DEFENDANTS’ MOTION TO DISMISS
COMPLAINT
CASE NO. 4:17-CV-05860-HSG

ORD
DER

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PURS
SUANT TO STIPULATION, IT IS S ORDER
SO
RED.

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DATED: JANU
UARY 3, 2018
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By:

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H
HON. HAYW
WOOD S. G
GILLIAM, JR
R.
U
UNITED ST
TATES DIST
TRICT JUD
DGE

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H OPKINS & C ARLEY
ATTORNEYS AT LAW
SAN JOSE

PALO ALTO

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462
26\2876780.1

STI
IPULATION AND ORDER TO MODIFY BRIEFING SC
A
T
B
CHEDULE FOR DEFENDAN
R
NTS’ MOTION TO DISMISS
N
S
CO
OMPLAINT
CASE NO 4:17-CV-058
O.
860-HSG