The opinion of the court was delivered by: Maxine M. Chesney United States District Judge
STIPULATION AND [PROPOSED] ORDER TO ADJOURN DEADLINE FOR PLAINTIFF VNUS MEDICAL TECHNOLOGIES, INC. TO RESPOND TO COUNTERCLAIMS OF TOTAL VEIN SOLUTIONS, LLC
WHEREAS, Plaintiff VNUS Medical Technologies, Inc. ("VNUS") filed a complaint against Defendant Total Vein Solutions, LLC, d/b/a Total Vein Systems ("TVS") in the above-captioned action on September 8, 2008 and filed a First Amended Complaint on November 14, 2008;
WHEREAS, TVS filed an answer and counterclaims against VNUS in response to the First Amended Complaint on December 4, 2008;
WHEREAS, good cause for an extension of time for VNUS to answer or otherwise respond to TVS's counterclaims includes enabling VNUS and their counsel to avoid conflict with the year-end holidays in connection with their investigation of TVS's counterclaims and preparation of a response to those counterclaims;
WHEREAS, such adjournment will not alter the date of any event or any deadline already fixed by Court order;
NOW THEREFORE, it is hereby stipulated and agreed by the respective parties by and through their counsel of record that VNUS's deadline to answer or otherwise respond to TVS's counterclaims is adjourned to January 12, 2009.
ATTORNEYS FOR PLAINTIFF VNUS MEDICAL TECHNOLOGIES, INC. Diem-Suong T. Nguyen Matthew B. Lehr (Bar No. 213139) Diem-Suong T. Nguyen (Bar No. 237557) David J. Lisson (Bar No. 250994) Chung G. Suh (Bar No. 244889) DAVIS POLK & WARDWELL 1600 El Camino Real Menlo Park, CA 94025 (650) 752-2000/(650) 752-2111 (fax) firstname.lastname@example.org email@example.com firstname.lastname@example.org email@example.com
ATTORNEYS FOR DEFENDANT TOTAL VEIN SOLUTIONS, LLC d/b/a TOTAL VEIN SYSTEMS John Karl Buche (Bar No. 239477) Sean Sullivan (Bar No. 254372) BUCHE & ASSOCIATES, PC 875 Prospect, Suite 305 La Jolla, CA 92037 Tel: (858) 812-2840 Fax: (858) 459-9120 firstname.lastname@example.org email@example.com
I hereby attest that I have on file written permission to sign this stipulation from all parties whose signatures are indicated by a "conformed" signature (/s/) within this e-filed document.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
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