Cisco Systems, Inc. et al v. Chung et al

Filing 140

ORDER GRANTING 139 STIPULATION FOR AN EXTENSION TO RESPOND TO DEFENDANTS' ADMINISTRATIVE MOTION TO FILE UNDER SEAL ** AS MODIFIED BY THE COURT ** by Judge Phyllis J. Hamilton. (pjhlc2S, COURT STAFF) (Filed on 9/15/2020)

1 John M. Desmarais (SBN 320875)
[e-mail]
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DESMARAIS LLP
3 101 California Street
San Francisco, CA 94111
4 [phone]
5 Justin P.D. Wilcox (admitted pro hac vice)
[e-mail]
6
Tamir Packin (SBN 317249)
7 [e-mail]
Steven M. Balcof (admitted pro hac vice)
8 [e-mail]
Carson Olsheski (admitted pro hac vice)
9 [e-mail]
10 David A. Frey (admitted pro hac vice)
[e-mail]
11 DESMARAIS LLP
230 Park Avenue
12 New York, NY 10169
[phone]
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14 Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND

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CISCO SYSTEMS, INC., a California
Corporation, CISCO TECHNOLOGY, INC., a
California Corporation
Plaintiffs,

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Case No.: 4:19-cv-07562-PJH
JOINT STIPULATION AND
[PROPOSED] ORDER FOR AN
EXTENSION OF TIME TO
RESPOND TO DEFENDANTS’
ADMINISTRATIVE MOTION TO
FILE UNDER SEAL

v.
PLANTRONICS, INC., a Delaware
Corporation, WILSON CHUNG, JAMES HE,
JEDD WILLIAMS, AND THOMAS
PUORRO individuals

**AS MODIFIED BY THE COURT**

Defendants.

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JOINT STIPULATION FOR AN EXTENSION OF TIME TO RESPOND
TO DEFENDANTS’ ADMINISTRATIVE MOTION TO FUS

4:19-cv-07562-PJH

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JOINT STIPULATION FOR AN EXTENSION OF TIME TO RESPOND DEFENDANTS’
ADMINISTRATIVE MOTION TO FILE UNDER SEAL

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Pursuant to Civil Local Rule 6-2, Plaintiffs’ Cisco Systems, Inc. and Cisco Technology, Inc.

3 (“Cisco”) and Defendants Plantronics, Inc., and Thomas Puorro (“Defendants”), by and through their
4 respective counsel of record, hereby stipulate as follows:
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1.

Whereas Defendants’ filed an Administrative Motion to Seal documents, including a

6 Motion to Strike, Cisco’s Trade Secret Disclosure, and other documents on September 10, 2020;

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2.

Whereas Plaintiffs’ Declaration In Support thereof is due on September 17, 2020;

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3.

Whereas Cisco contends there is good cause for the relief requested by this stipulation

9 for the reasons set forth in the concurrently filed Declaration of Carson Olsheski (the “Olsheski
10 Declaration”) in support of the Joint Stipulation for an Extension of Time to Respond to Defendants’
11 Administrative Motion to File Under Seal;
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4.

Whereas Defendants have agreed not to oppose, and to stipulate to Cisco’s requested

13 extension;
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5.

Whereas the parties agree that Cisco may have an extension to and including September

15 21, 2020 to file their declaration in support of Defendants’ Administrative Motion to File Under Seal;
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6.

Whereas this Stipulation is accompanied by the Olsheski Declaration;

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NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the parties, through

18 their respective counsel and subject to the Court’s approval, that: Plaintiffs’ shall now have until
19 September 21, 2020 to file a declaration in support of Defendants’ Administrative Motion to File
20 Under Seal.
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IT IS SO STIPULATED

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JOINT STIPULATION FOR AN EXTENSION OF TIME TO RESPOND
TO DEFENDANTS’ ADMINISTRATIVE MOTION TO FUS

4:19-cv-07562-PJH

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DATED: September 13, 2020
/s/ Jason Strabo
Jon Dean (SBN 184972)
[e-mail]
Russell Hayman (SBN 110643)
[e-mail]
Jason D. Strabo (SBN 246426)
[e-mail]
Michelle Lowery (SBN 302882)
[e-mail]
McDERMOTT WILL & EMERY LLP
2049 Century Park East, Suite 3200
Los Angeles, California 90067
T: [phone]
F: [phone]

/s/ Carson Olsheski
Carson Olsheski (admitted pro hac vice)
[e-mail]
DESMARAIS LLP
230 Park Avenue
New York, New York 10169
T: 212-351-3400
Attorney for Plaintiffs

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Attorneys for Defendants Plantronics, Inc. and
Thomas Puorro

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PURSUANT TO STIPULATION AND GOOD CAUSE APPEARING, IT IS HEREBY
ORDERED that Plaintiffs’ shall have until September 21, 2020 to file a declaration in support of
Defendants’ Administrative Motion to File Under Seal.
September 15
Dated: ___________, 2020

/s/ Phyllis J. Hamilton
___________________________________
Hon. Phyllis J. Hamilton
Chief Judge of the United States District Court

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JOINT STIPULATION FOR AN EXTENSION OF TIME TO RESPOND
TO DEFENDANTS’ ADMINISTRATIVE MOTION TO FUS

4:19-cv-07562-PJH