MSGI Security Solutions, Inc. v. Hyundai Syscomm Corporation et al

Filing 6

STIPULATION AND ORDER RE: 5 TO EXTEND TIME TO RESPOND TO PLAINTIFF'S COMPLAINT. Signed by Magistrate Judge Richard Seeborg on 8/13/09. (rslc2, COURT STAFF) (Filed on 8/12/2009)

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

Dennis Brown, CSBN 70284 Henry Chuang, CSBN 250628 111 North Market Street, Suite 1010 San Jose, CA 95113

*E-Filed 8/13/09*

Attorneys for Defendants: Hyundai Syscomm Corporation, Hyundai Syscomm Inc., Apro Media Corporation, Hirsch Group, LLLP, Hirsch Capital Corporation, Hyundai RFMon, Samuel Lee, Jack Choe, David Choe, Benjamin Byun, Wallace Benjamin Garst, Jr.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT COURT OF CALIFORNIA SAN JOSE DIVISION MSGI SECURITY SOLUTIONS, INC., a New York Corporation v. Plaintiffs, CASE NO.: C 09-03330-RS STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFFS COMPLAINT [L.R. 6-1(a)] Judge: Honorable Richard Seeborg

HYUNDAI SYSCOMM CORPORATION, a California corporation; HYUNDAI SYSCOMM INC., a Korean Company; APRO MEDIA CORPORATION, a Delaware corporation; APRO MEDIA CO., LTD, a Korean Company; HIRSCH GROUP LLLP, a Virginia Limited Liability Company; HIRSCH CAPITAL CORPORATION, a California CorporatiOn; HYUNDAI RFMON CORPORATION, a California Corporation; SAMUEL LEE; JACK CHOE; BENJAMIN BYUN; WALLACE BENJAMIN GARST, JR.; DAVID CHOE; AND does 1 through 50; Defendants.

Complaint Filed: July 21, 2009 Trial Date:

TO ALL PARTIES HEREIN AND THEIR RESPECTIVE ATTORNEYS OF RECORD: This stipulation is made pursuant to Local Rule 6-1(a) and is made between Plaintiff MSGI Security Solutions, Inc. (hereinafter "MSGI") and Defendants APRO MEDIA CORPORATION, HYUNDAI SYSCOMM, CORPORATION, HYUNDAI SYSCOMM INC., HIRSCH CAPITAL CORPORATION, HYUNDAI RFMON CORPORATION, WALLACE BENJAMIN GARST, JR.,

-1STIPULATION TO CONTINUE THE DATE TO FILE THE AMENDED COMPLAINT

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

DAVID CHOE, HIRSCH GROUP LLP (collectively known as "Served Defendants") who have been properly or purportedly served on or after July 23, 2009, by and through their respective counsel. The parties herein, agree and stipulate as follows: A. On or about July 21, 2009, this action was filed with the Northern District of California, San Jose Division. B. On or about July 23, 2009, Plaintiff MSGI attempted to or has stated that it has attempted to serve several of the defendants. C. On or about August 7, 2009, the Served Defendants contacted Plaintiff MSGI in regards to an extension of time to respond. D. On or about August 7, 2009, Plaintiff's counsel agreed to extend the time to respond to the Complaint in the instant Court up to and included August 21, 2009. Defendants specifically reserve the right to raise any issues in regards to service and jurisdiction. E. This stipulation does not alter the date of any event or any deadline already fixed by the Court.

IT IS HEREBY STIPULATED by and between the parties to the above-entitled actions, through their respective counsel: 1. The parties agree that the Served Defendants have up to and including August 21, 2009 to respond to Plaintiff's Complaint

Dated: August 11, 2009

GCA LAW PARTNERS LLP

By

/s/ Kathryn C. Curry Attorneys for MSGI SECURITY SOLUTIONS, -2-

STIPULATION TO CONTINUE THE DATE TO FILE THE AMENDED COMPLAINT

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
8/13/09

INC.

Dated: August 11, 2009

LAW OFFICES OF DENNIS D. BROWN

BY_________/s/_____________________ Dennis D. Brown Attorneys for Served Defendants AS GOOD CAUSE EXISTS, IT IS SO ORDERED:

Dated:________________________

_________________________________________ Honorable Judge Richard Seeborg

-3STIPULATION TO CONTINUE THE DATE TO FILE THE AMENDED COMPLAINT