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

Filing 19

STIPULATION AND ORDER EXTENDING TIME FOR DEFENDANTS TO RESPOND TO COMPLAINT re 18 . Signed by Judge Jeremy Fogel on 9/1/11. (dlm, COURT STAFF) (Filed on 9/9/2011)

1
2
3
4

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]

5
Attorneys for Defendants
6
7
UNITED STATES DISTRICT COURT

8

FOR THE NORTHERN DISTRICT OF CALIFORNIA

9

SAN JOSE DIVISION

10
11
12

CYPRESS SEMICONDUCTOR CORPORATION,
a Delaware Corporation,

14
15
16
17

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

Plaintiff,

13

Case Number CV-11-617-JF

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

Honorable Jeremy Fogel

Defendants.

18
19
20

Plaintiff and Defendants, by and through their respective undersigned counsel, stipulate and
agree as follows:

21

WHEREAS, on June 2, 2011, the Court So Ordered the parties’ initial stipulation

22

extending the time for Defendants to respond to the Complaint in this action to July 11, 2011; and

23

WHEREAS, on July 8, 2011, the Court So Ordered the parties’ second stipulation

24
25

extending the time for Defendants to respond to the Complaint in this action through and including
August 24, 2011; and

26
WHEREAS the parties are presently discussing the possible resolution of this dispute and
27
28

an additional thirty (30) days would facilitate those discussions; and
STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
TO RESPOND TO COMPLAINT - CV-11-617-JF

1

1

WHEREAS, accordingly, Defendants have met and conferred with Plaintiff and requested

2

an additional 30-day extension of the time for all Defendants to move against, answer or respond

3

to the Complaint (through and including September 23, 2011); and

4

WHEREAS, Plaintiff has consented to Defendants’ request;

5
6

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

7

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

8

answer or respond to the Complaint shall be extended from August 24, 2011 through and

9

including September 23, 2011.

10

In accordance with General Order 45 of the United States District Court for the Northern

11

District of California, I attest that concurrence in the filing of this document has been obtained

12

from the undersigned counsel.

13

DATED: August 22, 2011

Respectfully submitted,

14
By

/s/ Philip J. Wang
Philip J. Wang (SBN 218349)
Justin S. Chang (SBN 205925)
WANG & CHANG, A PROFESSIONAL
LAW CORPORATION
One Maritime Plaza, Suite 825
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

15
16
17
18
19
20
21

Attorneys for Plaintiff

22
23

By

27

/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]
[e-mail]

28

- and -

24
25
26

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

2

1

6

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]

7

Attorneys for Defendants

2
3
4
5

8
ATTESTATION CLAUSE
9
I, William J. Goines, am the ECF User whose ID and password are being used to file this
10
STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS TO
11
RESPOND TO COMPLAINT. In compliance with General Order 45, X.B., I hereby attest that
12
Philip J. Wang has concurred in this filing.
13
14
Date: August 22, 2011

GREENBERG TRAURIG, LLP

15
16

By: /s/ William J. Goines

17
18
19
20
21
22
23
24
25
26
27
28
STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
TO RESPOND TO COMPLAINT - CV-11-617-JF

3

1
2
3
4

PURSUANT TO STIPULATION, IT IS SO ORDERED.

DATED:

9/1
___________, 2011
The Honorable Jeremy Fogel
United States District Judge

5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

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

4