Gargale v. Fortinet, Inc.

Filing 19

STIPULATION AND ORDER TO EXTEND TIME IN WHICH DEFENDANT FORTINET, INC. MUST FILE A RESPONSIVE PLEADING & CONTINUING CMC DATE (approving docket no. 18 ). Case Management Conference set for 12/19/08 is CONTINUED to 1/30/2009 at 10:30 AM. Signed by Judge Jeremy Fogel on 12/1/08. (jflc2, COURT STAFF) (Filed on 12/1/2008)

**E-Filed 12/1/08** 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 v. FORTINET, INC. and DOES 1 through 50, Defendants. ENRICO GARGALE, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) 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: December 19, 2008 Proposed CMC Date: January 30, 2009 Before: Hon. Jeremy Fogel TERRY T. JOHNSON, State Bar No. 121569, [e-mail] CYNTHIA A. DY, State Bar No. 172761, [e-mail] JENNY L. DIXON, State Bar No. 192638, [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

WHEREAS, Plaintiff filed his Complaint on July 1, 2008; WHEREAS, Defendant Fortinet, Inc.'s responsive pleading is currently due on December 3, 2008; WHEREAS, the Rule 26(f) Report, initial disclosures, and Case Management Statement are currently due on December 11, 2008; WHEREAS, the Initial Case Management Conference is currently scheduled for December 19, 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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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 2009.

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 January 16,

2.

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

be filed on or before January 23, 2009. 3. The Initial Case Management Conference currently scheduled for December 19,

2008 is hereby continued until January 30, 2009, or to such later date as may be ordered by the Court.

Dated: November 25, 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: November 25, 2008

WILSON SONSINI GOODRICH & ROSATI Professional Corporation 650 Page Mill Road Palo Alto, CA 94304-1050 Telephone: [phone] Facsimile: [phone] By: /s/ Jenny L. Dixon Jenny L. Dixon 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 December 1, 2008 Dated: -------------------------November , 2008 2009. 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 January 16,

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

be filed on or before January 23, 2009. 3. The Initial Case Management Conference currently scheduled for December 19,

2008 is hereby continued until January 30, 2009, 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 25th day of November, 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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