Gargale v. Fortinet, Inc.

Filing 17

STIPULATION AND ORDER TO EXTEND TIME IN WHICH DEFENDANT FORTINET, INC. MUST FILE A RESPONSIVE PLEADING & CONTINUING CMC DATE (approving docket no. 16 ). Case Management Conference set for 12/19/2008 10:30 AM. Signed by Judge Jeremy Fogel on 10/30/08. (jflc2, COURT STAFF) (Filed on 10/30/2008)

**E-Filed 10/30/08** 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ENRICO GARGALE, Plaintiff, v. FORTINET, INC. and DOES 1 through 50, Defendants. TERRY T. JOHNSON, State Bar No. 121569, [e-mail] CYNTHIA A. DY, State Bar No. 172761, [e-mail] PAMELA E. GLAZNER, State Bar No. 247007, [e-mail] WILSON SONSINI GOODRICH & ROSATI Professional Corporation 650 Page Mill Road Palo Alto, CA 94304-1050 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant FORTINET, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

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CASE NO.: CV-08-3167-JF ----------------STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME IN WHICH DEFENDANT FORTINET, INC. MUST FILE A RESPONSIVE PLEADING & CONTINUING CMC DATE Current CMC Date: November 21, 2008 Proposed CMC Date: December 19, 2008 Before: Hon. Jeremy Fogel

WHEREAS, Plaintiff filed his Complaint on July 1, 2008; WHEREAS, Defendant Fortinet, Inc.'s responsive pleading is currently due on November 3, 2008; WHEREAS, the Rule 26(f) Report, initial disclosures, and Case Management Statement are currently due on November 11, 2008; WHEREAS, the Initial Case Management Conference is currently scheduled for November 21, 2008; WHEREAS, the parties desire to defer such deadlines in order to pursue settlement discussions;
STIP & [PROPOSED] ORDER EXTENDING TIME & CONTINUING CMC DATE, CASE NO. CV-08-3167-JF

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3506817_2.DOC

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2008.

NOW, THEREFORE, the parties, by and through their undersigned counsel of record, hereby agree and stipulate to the following: 1. Defendant Fortinet, Inc. will file a responsive pleading on or before December 3,

2.

The Rule 26(f) Report, initial disclosures, and Case Management Statement will

be filed on or before December 11, 2008. 3. The Initial Case Management Conference currently scheduled for November 21,

2008 is hereby continued until December 19, 2008, or to such later date as may be ordered by the Court.

Dated: October 29, 2008

Shook, Hardy & Bacon L.L.P. 333 Bush Street, Suite 600 San Francisco, CA 94104-2828 Telephone: [phone] Facsimile: [phone] By: /s/ Michael C. Osborne Michael C. Osborne Counsel for Plaintiff Enrico Gargale

Dated: October 29, 2008

WILSON SONSINI GOODRICH & ROSATI Professional Corporation 650 Page Mill Road Palo Alto, CA 94304-1050 Telephone: [phone] Facsimile: [phone] By: /s/ Cynthia A. Dy Cynthia A. Dy Counsel for Defendant Fortinet, Inc.

STIP & [PROPOSED] ORDER EXTENDING TIME & CONTINUING CMC DATE, CASE NO. CV-08-3167-JF

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: October 30 , 2008 2008. 2.

[PROPOSED] ORDER Based upon the above stipulation of the parties, and for good cause appearing therefor, IT IS HEREBY ORDERED THAT: 1. Defendant Fortinet, Inc. will file a responsive pleading on or before December 3,

The Rule 26(f) Report, initial disclosures, and Case Management Statement will

be filed on or before December 11, 2008. 3. The Initial Case Management Conference currently scheduled for November 21,

2008 is hereby continued until December 19, 2008, or to such later date as may be ordered by this Court.

Hon. Jeremy Fogel United States District Judge

STIP & [PROPOSED] ORDER EXTENDING TIME & CONTINUING CMC DATE, CASE NO. CV-08-3167-JF

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ATTESTATION PURSUANT TO GENERAL ORDER 45 I, Pamela E. Glazner, attest that concurrence in the filing of this document has been obtained from each of the signatories. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 29th day of October, 2008 at Palo Alto, California.

By:

/s/ Pamela E. Glazner Pamela E. Glazner

Counsel for Defendant Fortinet, Inc.

STIP & [PROPOSED] ORDER EXTENDING TIME & CONTINUING CMC DATE, CASE NO. CV-08-3167-JF

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