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Gofron v. Picsel Technologies

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


July 13, 2010

CARRIE GOFRON, J. WILLIAM VANKE, ASHWINI KUMAR, MATTHEW MIXON, AND DULCE GONZALEZ, PLAINTIFFS,
v.
PICSEL TECHNOLOGIES, INC., LESCIP T LIMITED FORMERLY PICSEL TECHNOLOGIES LIMITED, HAMSARD LIMITED, MASOOD JABBAR AND IMRAN KHAND, DEFENDANTS.

The opinion of the court was delivered by: Judge: Hon. Edward M. Chen

[Complaint Filed: August 31, 2009]

STIPULATION EXTENDING DEFENDANT LESCIP T LIMITED'S TIME TO RESPOND TO COMPLAINT PURSUANT TO LOCAL RULE 6-1(a)

Trial Date: None Set

WHEREAS on August 31, 2009, Plaintiffs filed their original Complaint in this action;

WHEREAS on May 21, 2010, Plaintiffs filed their First Amended Complaint, pursuant to which they, inter alia, added defendant LESCIP T. LIMITED ("Lescip") to the action;

WHEREAS Lescip is a UK-based company that entered into administration (the "Administration") on July 15, 2009, and John Bruce Cartwright and Graham Frost were appointed Joint Administrators of Lescip (the "Administrators");

WHEREAS on June 16, 2010, the Administrators were allegedly served with the First Amended Complaint;

WHEREAS if service is deemed proper, the due date for the Administrators of Lescip to plead, answer or otherwise respond to the First Amended Complaint would have been on or about July 7, 2010;

WHEREAS the Administrators of Lescip require additional time to evaluate the First Amended Complaint and plead, answer or otherwise respond to the First Amended Complaint;

WHEREAS the parties believe and agreed on July 7, 2010, that it is prudent, desirable and efficient to extend the time for the Administrators of Lescip to respond to the First Amended Complaint;

WHEREAS an extension of time until Tuesday, August 3, 2010 for the Administrators of Lescip to plead, answer or otherwise respond to the First Amended Complaint will not alter the date of any event or deadline already fixed by Court order in this action;

NOW THEREFORE, pursuant to Local Rule 6-1(a), it is hereby stipulated and agreed by and between Plaintiffs and the Administrators of Lescip that:

The Administrators of Lescip shall have through to and including Tuesday, August 3, 2010 to plead, answer or otherwise respond to the First Amended Complaint in this action.

This stipulation is entered into without waiver of any and all defenses available to the Administrators of Lescip, including without limitation, lack of personal jurisdiction, improper service and that commencing this action against Lescip is a violation of the moratorium in the Administration, and is not a concession that service has been effected on Lescip or the Administrators of Lescip.

IT IS SO STIPULATED

Dated: July 9, 2010 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP STEVEN B. SACKS Attorneys for Defendant LESCIP T. LIMITED

Dated: July 9, 2010 CRAIG A. MARR, ATTORNEY AT LAW CRAIG A. MARR Attorney for Plaintiffs

20100713

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