Interserve, Inc. et al v. Fusion Garage PTE. LTD

Filing 215

STIPULATION Seeking Stay Pending Settlement and [Proposed] Order by CrunchPad, Inc., Interserve, Inc.. (Bridges, Andrew) (Filed on 9/22/2011)

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Andrew P. Bridges (SBN: 122761)
[e-mail]
David S. Bloch (SBN: 184530)
[e-mail]
WINSTON & STRAWN LLP
101 California Street
San Francisco, CA 94111-5802
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Plaintiffs

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QUINN EMANUEL URQUHART & SULLIVAN, LLP
Claude M. Stern (Bar No. 96737)
[e-mail]
Evette Pennypacker (Bar No. 203515)
[e-mail]
555 Twin Dolphin Dr., 5th Floor
Redwood Shores, Ca 94065
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant

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101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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TECHCRUNCH, INC., et al.

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Plaintiffs,
vs.
FUSION GARAGE PTE. LTD.,

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Defendant.

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Case No. 3:09-cv-05812 RS
JOINT STIPULATION SEEKING STAY
PENDING SETTLEMENT AND
[PROPOSED] ORDER

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JOINT STIPULATION SEEKING STAY PENDING SETTLEMENT
SF:319633.4

Case No. 3:09-cv-05812 RS

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WHEREAS, the parties in this action have executed a Memorandum of Understanding
regarding final settlement of this case;
WHEREAS, the parties believe they will be in a position to execute a definitive agreement
within fourteen days;
WHEREAS, the parties are facing imminent deadlines as set forth in the March 31, 2011

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Case Management Scheduling Order (Docket Entry 206), as well as deadlines relating to ongoing

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discovery and motion practice;

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101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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WHEREAS, the parties agree that if the anticipated final agreement does not take place, they
will jointly seek reasonable rescheduling of all dates, deadlines, motions, and other activities;
NOW THEREFORE, it is hereby stipulated by the undersigned counsel on behalf of the
parties identified below that:
All pending deadlines, motions, notices, subpoenas, and hearing dates be suspended or stayed
pending anticipated final agreement.
The case be temporarily stayed pending execution of the settlement or a report that the
settlement was not executed.

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Dated: September 22, 2011

WINSTON & STRAWN LLP

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By:

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/s/
Andrew P. Bridges
David S. Bloch

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Attorneys for Plaintiffs

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Dated: September 22, 2011

QUINN EMANUEL URQUHART & SULLIVAN, LLP

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By:

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/s/
Claude M. Stern
Evette D. Pennypacker
Attorneys for Defendant

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JOINT STIPULATION SEEKING STAY PENDING SETTLEMENT
SF:319633.4

Case No. 3:09-cv-05812 RS

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I, Andrew P. Bridges, hereby attest, pursuant to N.D. Cal. General Order No. 45, that the
concurrence to the filing of this document has been obtained from each signatory hereto.

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By:

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/s/
Andrew P. Bridges

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101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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JOINT STIPULATION SEEKING STAY PENDING SETTLEMENT
SF:319633.4

Case No. 3:09-cv-05812 RS

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PURSUANT TO STIPULATION, IT IS HEREBY ORDERED:

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agreement.

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This case is hereby STAYED pending anticipated execution of a settlement

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All deadlines, motions, notices, subpoenas and hearing dates are SUSPENDED or

STAYED. The parties shall report the status of this case to the Court within fourteen days.

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Dated:

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, 2010

The Honorable Richard Seeborg
United States District Court Judge

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101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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JOINT STIPULATION SEEKING STAY PENDING SETTLEMENT
SF:319633.4

Case No. 3:09-cv-05812 RS