Gargale v. Fortinet, Inc.

Filing 25

STIPULATION AND ORDER re 20 to Extend Defendant's Time to Respond to Complaint. Signed by Judge Jeremy Fogel on 1/20/09. (dlm, COURT STAFF) (Filed on 1/23/2009)

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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

ENRICO GARGALE, Plaintiff, v. FORTINET, INC. and DOES 1 through 50, Defendants.

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CASE NO.: CV-08-3167-JF STIPULATION TO EXTEND DEFENDANT'S TIME TO RESPOND -----------------TO COMPLAINT; [PROPOSED] ORDER CMC Date: January 30, 2009 Before: Hon. Jeremy Fogel

WHEREAS, pursuant to the Court's Order dated December 1, 2008, Defendant Fortinet, Inc.'s response to Plaintiff's Complaint is currently due on January 16, 2009; WHEREAS, counsel for Plaintiff has agreed to extend the time within which Defendant's response to the Complaint shall be due;

STIP TO EXTEND DEF.'S TIME TO RESPOND TO COMPLAINT CASE NO. CV-08-3167-JF

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THEREFORE, the parties to this action, by and through their attorneys, hereby STIPULATE AND AGREE, subject to approval of the Court, that Defendant shall have until and including January 21, 2009 to respond to the Complaint. All other deadlines will remain the same. Dated: January 16, 2009 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: January 16, 2009 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.

[PROPOSED] ORDER Based upon the above stipulation of the parties, and for good cause appearing therefor, IT IS HEREBY ORDERED THAT: Defendant Fortinet, Inc. shall have until and including January 21, 2009 to respond to the Complaint. All other deadlines will remain the same. 20

Dated: January

, 2009

Hon. Jeremy Fogel United States District Judge

STIP TO EXTEND DEF.'S TIME TO RESPOND TO COMPLAINT 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 16th day of January, 2009 at Palo Alto, California.

By:

/s/ Pamela E. Glazner Pamela E. Glazner

Counsel for Defendant Fortinet, Inc.

STIP TO EXTEND DEF.'S TIME TO RESPOND TO COMPLAINT CASE NO. CV-08-3167-JF

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