UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO)
December 14, 2010
ADOBE SYSTEMS INCORPORATED,
RENEE NORWOOD, ET AL. DEFENDANTS.
The opinion of the court was delivered by: Hon. Susan Illston
STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND [PROPOSED] ORDER
Time: 2:30 p.m.
Court: ALL RELATED CLAIMS
PLAINTIFF Adobe Systems Incorporated ("Adobe"), by and through its counsel of record, and Defendant Renee Norwood ("Norwood"), by and through her counsel of record, hereby stipulate and request as follows: WHEREAS Adobe filed its complaint on or about August 13, 2010;
WHEREAS Norwood was served on or about September 18, 2010;
WHEREAS Norwood, through her counsel of record, Michael L. Rodenbaugh, of Rodenbaugh Law, and Karen J. Bernstein, of the Law Offices of Karen J. Bernstein, admitted pro hac vice, filed an Answer and Counterclaims/Third-Party Complaint on or about November 17,2010;
Adobe v. Norwood: Stipulation to Continue CMC - 1 - WHEREAS the Parties have stipulated to extend the time for Adobe and Third-Party Defendant Software and Information Industry Association ("SIIA") to file responses to the Counterclaims/Third-Party Complaint;
WHEREAS the Parties conducted a Rule 26 conference on or about November 23, 2010;
WHEREAS, at that time, the Parties had not yet agreed upon an ADR selection;
WHEREAS Karen J. Bernstein is currently in the process of withdrawing as counsel for
Norwood, and current representation of Norwood remains unclear;
WHEREAS the Parties began preparation of the Joint CMC Statement but have not yet finalized a draft nor agreed upon a selection for ADR due to the ambiguity of Norwood's represenation;
WHEREAS briefly continuing the Case Management Conference and all corresponding deadlines will provide the Parties with additional time to more fully brief the Court on Adobe and SIIA's positions on the Counterclaims as well as allow time for Norwood's counsel of record to withdraw and/or substitute representation; and Adobe v. Norwood: Stipulation to Continue CMC - 2 - NOW, THEREFORE, Adobe respectfully requests the Court continue the Joint Case to Management Conference for approximately sixty (60) days, or not earlier than February 15, 2011.
IT IS SO STIPULATED.
DATED: December 7, 2010 J. Andrew Coombs, A Professional Corp.
J. Andrew Coombs Nicole L. Drey
Attorneys for Plaintiff Adobe Systems Incorporated
DATED: December 7, 2010 Law Offices of Karen J. Bernstein
Karen J. Bernstein
Attorneys for Defendant Renee Norwood
[PROPOSED] ORDER PURSUANT TO REQUEST, IT IS SO ORDERED. DATED: 2010
UNITED STATES DISTRICT JUDGE
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