Freescale Semiconductor, Inc. v. Chipmos Technologies Inc
Filing
108
ORDER APPROVING 96 STIPULATED REQUEST TO EXTEND BRIEFING SCHEDULE FOR CHIPMOS'S MOTION FOR SUMMARY JUDGMENT. Signed by Judge Jeremy Fogel on 7/14/2011. (jflc2, COURT STAFF) (Filed on 7/14/2011)
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Greg L. Lippetz (State Bar No. 154228)
glippetz@jonesday.com
Jacqueline K. S. Lee (State Bar No. 247705)
jkslee@jonesday.com
JONES DAY
1755 Embarcadero Road
Palo Alto, CA 94303
Telephone: 650-739-3939
Facsimile:
650-739-3900
Attorneys for Plaintiff and
Counterclaim Defendant
FREESCALE SEMICONDUCTOR, INC.
**E-Filed 7/14/2011**
RONALD S. LEMIEUX (SB# 120822)
ronlemieux@paulhastings.com
VIDYA R. BHAKAR (SB# 220210)
vbhakar@cooley.com
SHANEE Y.W. NELSON (SB# 221310)
shaneenelson@paulhastings.com
COOLEY LLP
3000 El Camino Real
Five Palo Alto Square
Palo Alto, CA 94306-2155
Telephone: (650) 843-5000
Facsimile: (650) 849-7400
Attorneys for Defendant and
Counterclaim-Plaintiff
CHIPMOS TECHNOLOGIES, INC
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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Freescale Semiconductor, Inc.,
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Plaintiff,
v.
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ChipMOS Technologies, Inc.,
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Defendant.
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Case No. C-09-03689-JF-RS
STIPULATED REQUEST AND
------------------- ORDER TO EXTEND
[PROPOSED]
BRIEFING SCHEDULE FOR
CHIPMOS’S MOTION FOR
SUMMARY JUDGMENT
Date:
N/A
Time:
N/A
Courtroom: 3, 5th Floor
Hon. Jeremy Fogel
Judge:
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Pursuant to Local Rule 6-2, Plaintiff Freescale Semiconductor, Inc. (“Freescale”) and
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Defendant ChipMOS Technologies, Inc. (“ChipMOS,” and together with Freescale, the “Parties”)
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jointly submit this stipulated request to extend the briefing schedule for ChipMOS’s Motion for
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Summary Judgment.
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According to Civil Local Rule 7-2, “all motions must be filed, served and noticed in
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writing on the motion calendar of the assigned Judge for hearing not less than 35 days after
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service of the motion.” Civil Local Rule 7-3 provides that “[a]ny opposition to a motion must be
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served and filed not more than 14 days after the motion is served and filed” and that “[a]ny reply
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to an opposition must be served and filed by the moving party not more than 7 days after the
SVI-95020v1
STIPULATED REQUEST AND [PROPOSED] ORDER
TO EXTEND BRIEFING SCHEDULE
Case No. C-09-03689-JF-RS
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opposition is served and filed.”
On July 1, 2011, ChipMOS served on Freescale a Motion for Summary Judgment, noticed
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for hearing on August 12, 2011. Under Civil Local Rule 7-3, Freescale’s opposition brief to
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ChipMOS’s Motion for Summary Judgment would be due on July 15, and ChipMOS’s reply brief
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would be due on July 22. See Civ. L.R. 7-3. The Parties have agreed amongst themselves,
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subject to the Court’s approval, to permit (1) Freescale to file its opposition brief on July 22 and
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(2) ChipMOS to file its reply brief on July 29.
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Given the Parties’ agreement on the proposed schedule, the Parties request that the Court
set the briefing schedule for ChipMOS’s Motion for Summary Judgment as follows:
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July 22
Deadline to File Opposition Brief
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July 29
Deadline to File Reply Brief
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August 12
Hearing
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This extended briefing schedule would not affect the currently noticed hearing date of August 12,
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2011 and would have no other effect on the current case schedule. 1
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This request for an extension is supported by the Declaration of Jacqueline K. S. Lee, filed
concurrently herewith.
IT IS SO STIPULATED.
Dated: July 1, 2011
JONES DAY
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By: /s/ Jacqueline K. S. Lee
Jacqueline K. S. Lee
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Counsel for Plaintiff
FREESCALE SEMICONDUCTOR, INC.
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In accordance with General Order No. 45, Section X(B), the above signatory attests that
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Concurrence in the filing of this document has been obtained from the signatory below.
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Under the Parties’ proposed extended briefing schedule, the deadlines to file opposition
and reply briefs in connection with ChipMOS’s Motion for Summary Judgment will occur before,
and thus will not affect, the deadlines to file responses and replies in connection with dispositive
motions set forth in the Joint Schedule Order. See ECF No. 72.
SVI-95020v1
-1-
STIPULATED REQUEST AND [PROPOSED] ORDER
TO EXTEND BRIEFING SCHEDULE
Case No. C-09-03689-JF-RS
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Dated: July 1, 2011
COOLEY LLP
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By: /s/ Shanee Y. W. Nelson
Shanee Y. W. Nelson
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Counsel for Defendant
CHIPMOS TECHNOLOGIES, INC.
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IT IS SO ORDERED.
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7/14/2011
DATED: ________________________
By:
Hon. Jeremy Fogel
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SVI-95020v1
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STIPULATED REQUEST AND [PROPOSED] ORDER
TO EXTEND BRIEFING SCHEDULE
Case No. C-09-03689-JF-RS
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