Elan Microelectronics Corporation v. Apple, Inc.

Filing 440

STIPULATION (FOURTH) AND [PROPOSED] ORDER TO EXTEND DEADLINES TO ALLOW FOR FINALIZATION OF SETTLEMENT by Apple, Inc., Elan Microelectronics Corporation. (Mehta, Sonal) (Filed on 12/19/2011)

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YITAI HU (SBN 248085)
[e-mail]
SEAN P. DEBRUINE (SBN 168071)
[e-mail]
ELIZABETH H. RADER (SBN 184963)
[e-mail]
JANE HAN BU (SBN 240081)
[e-mail]
JENNIFER LIU (SBN 268990)
[e-mail]
PALANI P. RATHINASAMY (SBN 269852)
[e-mail]
ALSTON & BIRD LLP
275 Middlefield Road, Suite 150
Menlo Park, CA 94025-4008
Telephone: [phone]
Facsimile: 650-838-2001
Attorneys for Plaintiff
ELAN MICROELECTRONICS
CORPORATION

MATTHEW D. POWERS (Bar No. 104795)
[e-mail]
TENSEGRITY LAW GROUP LLP
201 Redwood Shores Parkway, Suite 401
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: [phone]
JARED BOBROW (Bar No. 133712)
[e-mail]
SONAL N. MEHTA (Bar No. 222086)
[e-mail]
DEREK WALTER (Bar No. 246322)
[e-mail]
NATHAN GREENBLATT (Bar No. 262279)
[e-mail]
WEIL, GOTSHAL & MANGES LLP
Silicon Valley Office
201 Redwood Shores Parkway
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant and
Counterclaim Plaintiff,
APPLE INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ELAN MICROELECTRONICS
CORPORATION,
Plaintiff and Counterclaim
Defendant,

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Case No. C-09-01531 RS (PSG)
FOURTH STIPULATION AND
[PROPOSED] ORDER TO EXTEND
DEADLINES TO ALLOW FOR
FINALIZATION OF SETTLEMENT

v.
Hon. Richard Seeborg
APPLE INC.,
Defendant and Counterclaim
Plaintiff.

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FOURTH STIPULATION AND [PROPOSED] ORDER TO
EXTEND DEADLINES

Case No. C-09-01531 RS (PSG)

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Defendant Apple, Inc. (“Apple”) and Plaintiff Elan Microelectronics Corporation
(“Elan”), by and through their respective counsel of record, hereby stipulate as follows:

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WHEREAS, on September 21, 2011, the parties attended a settlement conference

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before Magistrate Judge Spero and reached an agreement in principle to settle this litigation (D.I.

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432);

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WHEREAS, on October 24, 2011, the Court entered a Second Stipulation and

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Order to Extend Deadlines to Allow for Finalization of Settlement (D.I. 436), extending the fact

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discovery cutoff in this case to November 30, 2011, extending the deadline for Apple to produce

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certain documents to November 28, 2011, and requiring the parties to work together to propose a

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revised case schedule in the event a settlement is not finalized;
WHEREAS, the parties continue to work on drafting a settlement agreement to
formalize their agreement in principle to settle;

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

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through their respective counsel, that, subject to the Court’s approval, that the close of fact

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discovery be further extended to February 10, 2012.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
DATED: December 19, 2011

/s/ Sean P. DeBruine ______
Sean P. DeBruine

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ALSTON & BIRD LLP
Attorneys For Elan Microelectronics Corporation

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DATED: December 19, 2011

/s/ Sonal N. Mehta
Sonal N. Mehta

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WEIL, GOTSHAL & MANGES LLP
Attorneys for Apple Inc.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: __________________

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__________________________________
Honorable Richard Seeborg
United States District Court Judge

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FOURTH STIPULATION AND [PROPOSED] ORDER TO
EXTEND DEADLINES

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Case No. C-09-01531 RS (PSG)

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FILER’S ATTESTATION

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I, Sonal N. Mehta, am the ECF User whose ID and password are being used to file
this THIRD STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES TO
ALLOW FOR FINALIZATION OF SETTLEMENT. In compliance with General Order 45,
paragraph X.B. I hereby attest that Sean DeBruine has concurred in this filing.

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By:
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/s/ Sonal N. Mehta
Sonal N. Mehta

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FOURTH STIPULATION AND [PROPOSED] ORDER TO
EXTEND DEADLINES

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Case No. C-09-01531 RS (PSG)