Bell Sports, Inc. v. R.A. Allen Company, Inc.

Filing 16

STIPULATION AND ORDER extending time to respond to complaint; continuing case management conference to 11/2/2017. Signed by Judge Edward J. Davila on 09/05/2017. (ejdlc3, COURT STAFF) (Filed on 9/5/2017)

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MATTHEW B. LOWRIE (Pro Hac Vice pending)
[e-mail]
LUCAS I. SILVA (Pro Hac Vice pending)
[e-mail]
FOLEY & LARDNER LLP
111 HUNTINGTON AVENUE
SUITE 2500
BOSTON, MA 02199
TELEPHONE: [phone]
Facsimile: 617.342.4001

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EILEEN R. RIDLEY, CA Bar No. 151735
[e-mail]
FOLEY & LARDNER LLP
555 CALIFORNIA STREET
SUITE 1700
SAN FRANCISCO, CA 94104-1520
TELEPHONE: [phone]
FACSIMILE: 415.434.4507

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Attorneys for Plaintiff BELL SPORTS,
INC.

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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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BELL SPORTS, INC., A CALIFORNIA
CORPORATION,

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Plaintiff,
v.
R. A. ALLEN COMPANY, INC., A
MASSACHUSETTS CORPORATION,
Defendant.

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Case No. 5:17-cv-03142-EJD
STIPULATION TO EXTEND DEADLINE
TO RESPOND TO COMPLAINT AND
CONTINUE CASE MANAGEMENT
CONFERENCE (L.R. 6-1)

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STIPULATION TO EXTEND TIME AND CONTINUE CASE MANAGEMENT CONFERENCE
Case No. 5:17-cv-03142-EJD

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Pursuant to Local Rule 6-1, Defendant R. A. Allen Company, Inc. (“Defendant”), on the one

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hand, and Plaintiff Bell Sports, Inc. (“Plaintiff”), on the other, hereby stipulate, by and through their

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respective counsel of record, as follows:

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RECITALS

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WHEREAS, the Complaint in this action was filed on May 31, 2017;

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WHEREAS, the Complaint was served on the Defendant on or about July 18, 2017;

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WHEREAS, the parties previously requested extensions of the deadline to respond to the

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Complaint in this action on August 1, 2017 and August 17, 2017;
WHEREAS, the parties now request that Defendant’s deadline to respond to the Complaint be
extended to September 22, 2017;
WHEREAS, a Case Management Conference in this matter is scheduled to be held on September
14, 2017 at 1:00 p.m.;
WHEREAS, the parties further request a continuance of the Case Management Conference to a
time at the Court’s convenience but after September 22, 2017;
WHEREAS, this extension of time and continuance are sought because the parties continue to
engage in good faith settlement discussions, but additional time is necessary;
WHEREAS, the parties believe the requested extension of time and continuance will be
sufficient to allow them to complete their ongoing settlement discussions:

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STIPULATION

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THEREFORE, IT IS STIPULATED AND AGREED, by and between the Defendant and

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Plaintiff, through their respective counsel, that the deadline for the Defendant to file its response to the

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Complaint shall be extended to September 22, 2017, and the Case Management Conference shall be

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continued to a date and time that is convenience for the Court on or after September 25, 2017.

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IT IS SO STIPULATED.

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STIPULATION TO EXTEND TIME AND CONTINUE CASE MANAGEMENT CONFERENCE
Case No. 5:17-cv-03142-EJD
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DATED: August 31, 2017

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/s/ _____________
James E. Gallagher
Attorney for Defendant
R. A. ALLEN COMPANY, INC. A CALIFORNIA
CORPORATION

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DAVIS MALM & D'AGOSTINE, P.C.
James E. Gallagher

DATED: August 31, 2017

FOLEY & LARDNER LLP
Eileen R. Ridley
Matthew B. Lowrie (Pro Hac Vice Pending)
Lucas I. Silva (Pro Hac Vice Pending)
/s/ _____________
Eileen R. Ridley
Attorneys for Plaintiff
BELL SPORTS, INC.

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Pursuant to the parties' stipulation, the deadline for Defendant to file its response to the Complaint is
extended to September 22, 2017. The case management conference is continued to November 2, 2017 at
10:00 a.m. The parties shall file a joint case management statement no later than
October 23, 2017.
DATED: Sept. 5, 2017

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EDWARD J. DAVILA
United States District Judge

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STIPULATION TO EXTEND TIME AND CONTINUE CASE MANAGEMENT CONFERENCE
Case No. 5:17-cv-03142-EJD
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SIGNATURE ATTESTATION
Pursuant to Local Rule 5-1(i)(3), I hereby attest that concurrence in the filing of this
Stipulation has been obtained from all signatories to the Stipulation.

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DATED: August 31, 2017

FOLEY & LARDNER LLP
Eileen R. Ridley
Matthew B. Lowrie (Pro Hac Vice Pending)
Lucas I. Silva (Pro Hac Vice Pending)

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/s/ _____________
Eileen R. Ridley
Attorneys for Plaintiff
BELL SPORTS, INC..

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STIPULATION TO EXTEND TIME AND CONTINUE CASE MANAGEMENT CONFERENCE
Case No. 5:17-cv-03142-EJD
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