Advanced Engineering Solution, Inc v. Paccar, Inc. et al

Filing 25

Order by Hon. Lucy H. Koh granting 23 Stipulation.(lhklc1, COURT STAFF) (Filed on 4/26/2012)

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Case5:12-cv-00986-LHK Document23 Filed04/25/12 Page1 of 4 1 2 3 4 5 6 7 BINGHAM MCCUTCHEN LLP Thane D. Scott (pro hac vice) One Federal Street Boston, MA 02110-1726 Telephone: 617.951.8000 Facsimile: 617.951.8736 thane.scott@bingham.com Rianne E. Rocca (SBN 221640) Three Embarcadero Center San Francisco, CA 94111-4067 Telephone: 415.393.2000 Facsimile: 415.393.2286 rianne.rocca@bingham.com 8 9 Attorneys for Defendant, Parametric Technology Corporation 10 UNITED STATES DISTRICT COURT 11 NORTHERN DISTRICT OF CALIFORNIA 12 SAN JOSE DIVISION 13 14 15 ADVANCED ENGINEERING SOLUTION, INC., a California corporation, Plaintiff, 16 v. 17 18 19 20 21 22 No. CV12-00986 (LHK) STIPULATION AND [PROPOSED] ORDER RE EXTENSION OF TIME TO RESPOND TO THE PLAINTIFF’S COMPLAINT PACCAR, INC., a Delaware corporation; KENWORTH TRUCK COMPANY, an unknown entity; KALYPSO, INC., a corporation; PARAMETRIC TECHNOLOGY CORPORATION, a Massachusetts corporation; ANDREW TIMM, an individual; JORDAN REYNOLDS, an individual; and DOES 1 through 100, inclusive,, Defendants. 23 24 25 26 27 28 A/74911956.1/0123415-0000359984 STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT (CV12-00986) (LHK) Case5:12-cv-00986-LHK Document23 Filed04/25/12 Page2 of 4 1 Plaintiff, Advanced Engineering Solutions, Inc., and Defendant, Parametric 2 Technology Corporation (“PTC”), by and through their counsel of record, hereby submit the 3 following stipulation pursuant to Local Rule 6-2: 4 WHEREAS Plaintiff filed its Complaint on February 27, 2012; 5 WHEREAS, counsel stipulated to an initial 30-day extension of time to respond to the 6 Complaint, such that PTC’s response is currently due on April 30, 2012; 7 8 WHEREAS Plaintiff’s current counsel, The Williams Firm, filed a stipulation and proposed order requesting withdrawal as Plaintiff’s counsel on April 20, 2012; 9 10 WHEREAS a second extension of time would allow Plaintiff adequate time to seek substitute counsel before PTC files its response to Plaintiff’s Complaint; 11 12 WHEREAS extending PTC’s time to respond to the Complaint will not alter the date of any other event or deadline already fixed by the Court; 13 14 THEREFORE, Plaintiff and Defendant, by their respective counsel, stipulate and agree as follows: 15 1. The deadline for PTC to respond to the Complaint shall be extended up to and 16 including ten (10) days after Plaintiff’s successor counsel files its notice of appearance in this 17 case. 18 IT IS SO STIPULATED. 19 DATED: April 25, 2012 Bingham McCutchen LLP 20 By: /s/ Rianne E. Rocca 21 Attorney for Defendant Parametric Technology Corporation 22 23 The Williams Firm 24 25 By: /s/ D. Alexander Floum 26 Attorney for Plaintiff Advanced Engineering Solutions, Inc. 27 28 A/74911956.1/0123415-0000359984 2 STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT (CV12-00986) (LHK) Case5:12-cv-00986-LHK Document23 Filed04/25/12 Page3 of 4 1 [PROPOSED] ORDER 2 PURSUANT TO STIPULATION, IT IS SO ORDERED. 3 April 26, 2012 Dated: _____________________ The Honorable Lucy H. Koh Judge, United States District Court 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 A/74911956.1/0123415-0000359984 3 STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT (CV12-00986) (LHK)

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