Incorp Services, Inc., v. Legalzoom.com, Inc.,

Filing 31

STIPULATION re 17 Amended Complaint ; Third Stipulation and [Proposed] Order Extending Time to File Response to First Amended Complaint by Defendant Legalzoom.com, Inc.,. (Jassy, Jean-Paul)

1 BOSTWICK & JASSY LLP 2

Gary L. Bostwick (admitted pro hac vice) [e-mail] Jean-Paul Jassy (admitted pro hac vice) 3 [e-mail] 4 12400 Wilshire Boulevard, Suite 400 Los Angeles, California 90025 5 Tel: [phone] Fax: [phone]

6

7 Attorneys for Defendant
LegalZoom.com, Inc.

8

9 Karl S. Kronenberger (admitted pro hac vice)
150 Post Street, Suite 520 San Francisco, CA 94108 11 Telephone: [phone] Facsimile: [phone] 12 [e-mail]

KRONENBERGER BURGOYNE, LLP

10

13 Attorneys for Plaintiff 14 InCorp Services, Inc. 15 16 17
UNITED STATES DISTRICT COURT DISTRICT OF NEVADA Case No. 2:09-CV-00273-RJH-(LRL) THIRD STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO FILE RESPONSE TO FIRST AMENDED COMPLAINT (Third Request)

INCORP SERVICES, INC., a Nevada 18 corporation,

19 20 21
v.

Plaintiff,

LEGALZOOM.COM, INC., a Delaware 22 corporation,

23 24 25

Defendant.

Plaintiff Incorp Services, Inc. ("Incorp") filed a First Amended Complaint ("FAC")

26 on April 6, 2009. Incorp and Defendant LegalZoom.com, Inc. ("LegalZoom") hereby 27 stipulate that a responsive pleading or motion relating to the FAC may be filed up to and 28 including May 27, 2009. -1-

THIRD STIPULATION FOR EXTENSION OF TIME TO RESPOND TO FIRST AMENDED COMPLAINT

1

This is the third extension sought by LegalZoom relating to the FAC. The first

2 stipulation, extending the time to respond to May 6, 2009, was approved by order of the 3 Court on April 10, 2009. The second stipulation, extending the time to respond to May 13, 4 2009, was approved by order of the Court on May 4, 2009. 5 This extension is sought because, since the last extension, the parties have made

6 significant progress in attempting to resolve the issues raised in this action, and counsel for 7 the parties represent to the Court that they are highly optimistic that a final resolution will 8 be achieved before May 27, 2009. In order to permit the parties' discussions to proceed 9 without either party incurring potentially unnecessary fees and expenses, LegalZoom and 10 InCorp stipulate that it would be in the interests of the parties and judicial economy for 11 LegalZoom to have an extension until and including May 27, 2009 to answer, move or 12 otherwise respond to the FAC. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
JUDGE, UNITED STATES DISTRICT COURT DATED: ___________________ By /s/ Karl S. Kronenberger KARL S. KRONENBERGER Attorneys for Plaintiff InCorp Services, Inc. IT IS SO ORDERED: DATED: May 11, 2009 By DATED: May 11, 2009 BOSTWICK & JASSY LLP

/s/ Jean-Paul Jassy JEAN-PAUL JASSY Attorneys for Defendant LegalZoom.com, Inc.

KRONENBERGER BURGOYNE, LLP

-2-

THIRD STIPULATION FOR EXTENSION OF TIME TO RESPOND TO FIRST AMENDED COMPLAINT