U.S. Foodservice, Inc. v. M V Trading, Inc.

Filing 20

CORRECTED STIPULATION AND ORDER EXTENDING TIME TO RESPOND TO COMPLAINT AND FOR RELIEF FROM CASE MANAGEMENT SCHEDULE (approving 18 ). Case Management Conference set for 8/5/2011 10:30 AM. Signed by Judge Jeremy Fogel on 5/31/2011. (jflc2, COURT STAFF) (Filed on 5/31/2011)

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**E-Filed 5/31/2011**

Perry J. Narancic, SBN 206820
NARANCIC & KATZMAN, PC
325 Sharon Park Drive, #736
Menlo Park, CA 94025
www.technologylitigationcounsel.com
[e-mail]
Tel: [phone]
Fax: [phone]

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Attorneys for Defendant
MV TRADING, INC. dba MV TRADING, CO.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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U.S. FOODSERVICE, INC.,

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Plaintiff,
v.
MV TRADING, INC. dba MV TRADING, CO.,
Defendants.

CASE NO. 11 CV 1362 EDL
CORRECTED
STIPULATION AND ------------------[PROPOSED]
ORDER EXTENDING TIME TO
RESPOND TO COMPLAINT AND FOR
RELIEF FROM CASE MANAGEMENT
SCHEDULE
(Civ. L.R. 6-1(a))

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Pursuant to Civ. L. R. 6-1(a), Plaintiff U.S. Foodservice, Inc. and Defendant MV Trading,
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Inc. dba MV Trading, Co., by and through their respective counsel, stipulate and agree as follows:
WHEREAS Plaintiff U.S. Foodservice, Inc. served its Complaint for, inter alia, trademark
infringement on March 23, 2011;
WHEREAS Defendant MV Trading, Inc. dba MV Trading, Co. currently has until May 26,
2011 to answer or respond to the Complaint;
WHEREAS the parties previously stipulated to a 28-day extension of time for Defendant

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MV Trading, Inc. dba MV Trading, Co. to respond to Plaintiff’s Complaint, from April 14, 2011 to
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Stipulation to Extend Time and Continue Case Management Dates
U.S. Foodservice, Inc. v. MV Trading, Case No. 11-1362 EDL

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May 12, 2011, and to a 14-day second extension of time from May 12, 2011 through May 26,

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2011;

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WHEREAS pursuant to the Order Setting Initial Case Management Conference and ADR
Deadlines (“Case Management Order”), June 7, 2011 is the deadline for the parties to meet and

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confer pursuant to F.R. Civ.P. 26(f) and to either select an ADR process or notify the Court of the
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need for an ADR phone conference pursuant to Civ. L.R. 16-8 and ADR L.R. 3-5;
WHEREAS the parties are attempting to amicably resolve the litigation pending between

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them;

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IT IS HEREBY STIPULATED AND AGREED that Defendant MV Trading, Inc. dba MV

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Trading, Co. shall have until June 9, 2011 to answer or otherwise respond to Plaintiff’s Complaint.

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IT IS FURTHER STIPULATED AND AGREED that the parties hereto jointly request that

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each of the dates in the Case Management Order, including the case management conference, be
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extended by 30 days.

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DATED: May 26, 2011

SCHIFF HARDIN LLP

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By

/s/ Sarah D. Youngblood
Sarah D. Youngblood

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Attorneys for Plaintiff
U.S. FOODSERVICE, INC.

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Stipulation to Extend Time and Continue Case Management Dates
U.S. Foodservice, Inc. v. MV Trading, Case No. 11-1362 EDL

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DATED: May 26, 2011

NARANCIC & KATZMAN, P.C.

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By

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/s/ Perry J. Narancic
Perry J. Narancic

Attorneys for Defendant
MV TRADING, INC. dba MV TRADING, CO.

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DECLARATION OF CONSENT

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I, Perry J. Narancic, hereby declare pursuant to General Order 45, §X.B, that I have

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obtained concurrence in the filing of this Stipulation To Extend Time To Respond To Complaint

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and for Relief From Case Management Schedule from Sarah D. Youngblood, Esq.
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I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
Executed this 26th day of May, 2011.

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/s/ Perry J. Narancic

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ORDER
Pursuant to stipulation of the parties and good cause appearing,

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IT IS SO ORDERED.
The case management conference in the above-captioned case will be held on
10:30 am.
August 5
________________, 2011 at ----------3:00 p.m.

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5/31/2011
Dated: ________________________

________________________________________
-------------United States Magistrate Judge
District

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Stipulation to Extend Time and Continue Case Management Dates
U.S. Foodservice, Inc. v. MV Trading, Case No. 11-1362 EDL