Hantz Software, LLC v. Sage Intacct, Inc.
Filing
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ORDER by Judge Haywood S. Gilliam, Jr. Granting 38 Stipulation to Extend Briefing Schedule and Time to File Amended Complaint.(ndrS, COURT STAFF) (Filed on 6/3/2021)
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Lewis Emery Hudnell III (CA SBN 218736)
lewis@hudnelllaw.com
HUDNELL LAW GROUP
800 W. El Camino Real, Suite 180
Mountain View, CA 94040
Telephone: (650) 564-3698
Jason W. Wolff (CA SBN 215819)
wolff@fr.com
FISH & RICHARDSON P.C.
12860 El Camino Real, Ste. 400
San Diego, CA 92130
Telephone: (858) 678-5070
Facsimile: (858) 678-5099
Jon VanOphem (Admitted Pro Hac Vice)
john@vanophemiplaw.com
VANOPHEM IP LAW PLC
1585 S. Hickory Ridge Rd.
Milford, MI 48380
Telephone: (248) 817-8913
Lauren Degnan (Admitted Pro Hac Vice)
degnan@fr.com
FISH & RICHARDSON P.C.
1000 Maine Ave. SW
Washington, DC 20024
Telephone: (202) 626-6392
David J. Shea (Admitted Pro Hac Vice)
david.shea@sadplaw.com
26100 American Drive #2
Southfield, MI 48034
Telephone: (248) 354-0224
Robert Courtney (CA SBN 248392)
courtney@fr.com
FISH & RICHARDSON P.C.
3200 RBC Plaza
60 South Sixth Street
Minneapolis, MN 55402
Telephone: (612) 335-5070
Facsimile: (612) 288-9696
Attorneys for Plaintiff
HANTZ SOFTWARE, LLC
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Attorneys for Defendant
SAGE INTACCT, INC.
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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HANTZ SOFTWARE, LLC., a Michigan
Limited Liability Company,
Case No. 4:21-cv-01987-HSG
Plaintiff,
v.
SAGE INTACCT, INC., a Delaware Corporation,
JOINT STIPULATION AND ORDER FOR
EXTENSION OF MOTION TO DISMISS
BRIEFING SCHEDULE AND
EXTENSION OF TIME TO FILE
AMENDED COMPLAINT
Defendant.
Under Local Rule 6-2, Plaintiff Hantz Software, LLC’s (“Hantz”) and Defendant Sage
Intacct, Inc. (“Sage”), by and through their respective undersigned counsel, stipulate as follows:
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JOINT STIPULATION AND ORDER FOR EXTENSION OF MOTION
TO DISMISS BRIEFING SCHEDULE AND EXTENSION OF TIME TO
FILE AMENDED COMPLAINT
Case No. 4:21-cv-01987-HSG
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WHEREAS, Sage filed a Motion to Dismiss Complaint Pursuant to Fed. R. Civ. P. 12
(b)(6) in the present lawsuit on May 13, 2021;
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WHEREAS, on May 21, 2021, the Court granted the parties’ stipulation to extend the time
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for Hantz to respond to the Motion from May 27, 2021 to June 3, 2021 and for Sage to reply from
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June 3, 2021 to June 10, 2021 (Dkt. No. 35);
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WHEREAS, under Fed. R. Civ. P. 15(a)(1)(B), the deadline for Hantz tor file an Amended
Complaint as a matter of course is June 3, 2021.
WHEREAS, Sage does not oppose Hantz’s request for a 7-day extension of time for Hantz
to file a response to the Motion from June 3, 2021 to June 10, 2021 and for Sage to file a reply
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from June 10, 2021 to June 17, 2021 and a 7-day extension of time for Hantz to file an Amended
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Complaint from June 3, 2021 to June 10, 2021;
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WHEREAS, this extension of time will not alter the date of any event or any deadline that
the Court has already fixed, including the July 29, 2021 hearing date for the Motion; and
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THEREFORE, IT IS HEREBY STIPULATED that Hantz shall have up to and including
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June 10, 2021 to file a response to Sage’s Motion to Dismiss and Sage shall have up to and
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including June 17, 2021 to file its reply to Hantz’s response. Hantz also shall have up to and
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including June 10, 2021 to file an Amended Complaint. The parties respectfully jointly request
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that the Court issue an order modifying the motion to dismiss briefing schedule and the deadline
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to file an Amended Complaint in this case accordingly.
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
Dated: June 3, 2021
HUDNELL LAW GROUP P.C.
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By: /s/Lewis E. Hudnell, III
Lewis E. Hudnell, III
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Attorney for Plaintiff
HANTZ SOFTWARE, LLC
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JOINT STIPULATION AND ----------------- ORDER FOR EXTENSION
[PROPOSED]
OF MOTION TO DISMISS BRIEFING SCHEDULE AND EXTENSION
OF TIME TO FILE AMENDED COMPLAINT
Case No. 4:21-cv-01987-HSG
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Dated: June 3, 2021
FISH & RICHARDSON P.C.
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By: /s/Robert Courtney (with permission)
Robert Courtney
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Attorney for Defendant
SAGE INTACCT, INC.
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JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION
--------------OF MOTION TO DISMISS BRIEFING SCHEDULE AND EXTENSION
OF TIME TO FILE AMENDED COMPLAINT
Case No. 4:21-cv-01987-HSG
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ATTESTATION
Under Civ. Local Rule 5.1(i)(3) regarding signatures, I attest under penalty of perjury that
concurrence in the filing of this document has been obtained from counsel for Sage.
Dated: June 3, 2021
HUDNELL LAW GROUP P.C.
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By: /s/Lewis E. Hudnell, III
Lewis E. Hudnell, III
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Attorney for Plaintiff
HANTZ SOFTWARE, LLC
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JOINT STIPULATION AND ----------------- ORDER FOR EXTENSION
[PROPOSED]
OF MOTION TO DISMISS BRIEFING SCHEDULE AND EXTENSION
OF TIME TO FILE AMENDED COMPLAINT
Case No. 4:21-cv-01987-HSG
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IT IS SO ORDERED.
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6/3/2021
Dated: ____________________
_______________________________________
Hon. Haywood S. Gilliam, Jr.
United States District Court Judge
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JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION
---------------OF MOTION TO DISMISS BRIEFING SCHEDULE AND EXTENSION
OF TIME TO FILE AMENDED COMPLAINT
Case No. 4:21-cv-01987-HSG
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