Cypress Semiconductor Corporation v. Deutsche Bank Securities, Inc. et al

Filing 17

STIPULATION AND ORDER EXTENDING TIME FOR DEFENDANTS TO RESPOND TO COMPLAINT re 16 . Signed by Judge Jeremy Fogel on 7/8/11. (dlm, COURT STAFF) (Filed on 7/19/2011)

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William J. Goines (SBN 61290)
Greenberg Traurig, LLP
1900 University Avenue, 5th Floor
East Palo Alto, CA 94303
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendants
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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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CYPRESS SEMICONDUCTOR CORPORATION,
a Delaware Corporation,

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------------------STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME FOR
DEFENDANTS TO RESPOND TO
COMPLAINT

Plaintiff,

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v.

DEUTSCHE BANK SECURITIES INC., a
Delaware Corporation, DEUTSCHE BANK ALEX.
BROWN, a Division of Deutsche Bank Securities
Inc., and DEUTSCHE BANK AG,

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Case Number CV-11-617-JF

Honorable Jeremy Fogel

Defendants.

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Plaintiff and Defendants, by and through their respective undersigned counsel, stipulate and
agree as follows:
WHEREAS, on June 2, 2011, the Court So Ordered the parties’ initial stipulation

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extending the time for Defendants to respond to the Complaint in this action through and including

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July 11, 2011;

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WHEREAS, Defendants have met and conferred with Plaintiff and requested an additional
45-day extension of the time for all Defendants to move against, answer or respond to the

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Complaint (through and including August 25, 2011); and
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WHEREAS, Plaintiff has consented to Defendants’ request;
STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
TO RESPOND TO COMPLAINT - CV-11-617-JF

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IT IS HEREBY STIPULATED, by and between Plaintiff and Defendants, through their

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respective counsel, and subject to Court approval, that the time for all Defendants to move against,

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answer or respond to the Complaint shall be extended from July 11, 2011 through and including

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August 24, 2011.

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In accordance with General Order 45 of the United States District Court for the Northern
District of California, I attest that concurrence in the filing of this document has been obtained
from the undersigned counsel.
DATED: June 29, 2011

Respectfully submitted,

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By

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/s/ Philip J. Wang
Philip J. Wang (SBN 218349)
Justin S. Chang (SBN 205925)
LAW OFFICE OF PHILIP J. WANG
160 Bovet Rd. Ste. 310
San Mateo, California 94402
Telephone: [phone]
[e-mail]
[e-mail]

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Attorneys for Plaintiff

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By

/s/ William J. Goines
William J. Goines (SBN 61290)
GREENBERG TRAURIG, LLP
1900 University Avenue, 5th Floor
East Palo Alto, CA 94303
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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- and -

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
TO RESPOND TO COMPLAINT - CV-11-617-JF

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Stephen L. Saxl (Pro Hac Vice Motion
To Be Filed)
Toby S. Soli (Pro Hac Vice Motion
To Be Filed)
GREENBERG TRAURIG, LLP
200 Park Avenue
New York, New York 10166
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for Defendants

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ATTESTATION CLAUSE
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I, William J. Goines, am the ECF User whose ID and password are being used to file this
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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS TO
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RESPOND TO COMPLAINT. In compliance with General Order 45, X.B., I hereby attest that
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Philip J. Wang has concurred in this filing.
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Date: June 29, 2011

GREENBERG TRAURIG, LLP

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By: /s/ William J. Goines

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
TO RESPOND TO COMPLAINT - CV-11-617-JF

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

DATED:

7/8
___________, 2011
The Honorable Jeremy Fogel
United States District Judge

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
TO RESPOND TO COMPLAINT - CV-11-617-JF

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