ForageSF LLC et al v. Forage, Inc.

Filing 18

JOINT STIPULATION AND ORDER 17 Extending Time to Respond to the Initial Complaint. Signed by Judge Ronald M. Whyte on 1/16/15. (jgS, COURT STAFF) (Filed on 1/16/2015)

1 WARREN LEX LLP
Matthew S. Warren (Cal. Bar No. 230565)
2 Erika H. Mayo (Cal. Bar No. 295570)
2261 Market Street, No. 606
3 San Francisco, California, 94114
[e-mail]
4 [phone]
[phone] facsimile
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Attorneys for Plaintiffs
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COOLEY LLP
JOHN W. CRITTENDEN (101634)
CHANTAL Z. HWANG (275236)
101 California Street, 5th Floor
San Francisco, CA 94111-5800
[e-mail]
[e-mail]
[phone]
[phone] facsimile
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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12 FORAGESF LLC, FORAGE KITCHENS,
LLC, and FORAGE KITCHEN OAKLAND,
13 LLC,
Plaintiffs,

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v.

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16 FORAGE, INC.,

CASE NO. 14-4939-RMW
JOINT STIPULATION
AND [] ORDER
EXTENDING TIME TO RESPOND
TO THE INITIAL COMPLAINT
[Civil Local Rule 6-2]

Defendant.

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Under Civil Local Rule 6-2, Plaintiffs ForageSF LLC, Forage Kitchens, LLC, and Forage

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21 Kitchen Oakland, LLC (“Plaintiffs”) and Defendant Forage, Inc. (“Defendant”) (collectively with
22 Plaintiffs, “the Parties”) stipulate and jointly request that the Court continue the deadline for
23 Defendant’s response to the Complaint, as follows:
WHEREAS, on December 9, 2014, to avoid an entry of default against the Defendant,

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25 Defendant requested and Plaintiffs agreed to stipulate to an extension of time for Defendant to
26 answer or otherwise respond to the Complaint until December 15, 2015 (Docket No. 16);
WHEREAS, on December 10, 2014, the Parties commenced settlement discussions;

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tT

NO. 14-4939-RMW
STIPULATION AND ORDER EXTENDING TIME TO RESPOND

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WHEREAS, on December 11, 2014, to facilitate their settlement discussions, Defendant

2 requested and Plaintiffs agreed to stipulate to an extension of time for Defendant to respond to the
3 Complaint until January 5, 2016 (Docket No. 16);
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WHEREAS, on December 31, 2014, the parties and their counsel met in person to discuss

5 settlement, and reached a settlement in principle;
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WHEREAS, to facilitate preparation of a written settlement agreement, the Parties hereby

7 agree, under Civil Local Rule 6-2(a), to extend further Defendant’s time to respond to the
8 Complaint until and including January 16, 2015;
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WHEREAS, the Parties do not expect that the requested extension will impact or alter the

10 date of any event or deadline already fixed by Court Order;
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THE PARTIES HEREBY STIPULATE and jointly request that the Court extend the

12 January 5, 2015 deadline to respond to the Complaint until and including January 16, 2015.
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14 Date: January 5, 2015

Respectfully submitted,

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WARREN LEX LLP

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Matthew S. Warren
Attorneys for ForageSF LLC, Forage Kitchens, LLC, and
Forage Kitchen Oakland, LLC.
COOLEY LLP
/s/ John W. Crittenden
John W. Crittenden
Attorneys for Forage, Inc.

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24 Date: _______, 2015

AS STIPULATED, IT IS SO ORDERED.

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Honorable Ronald M. Whyte
United States District Judge

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NO. 14-4939-RMW
-2STIPULATION AND ORDER EXTENDING TIME TO RESPOND