UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
April 15, 2011
INTERNATIONAL BUSINESS MACHINES CORPORATION, PLAINTIFF,
The opinion of the court was delivered by: The Honorable Jeffrey S. White United States District Judge Northern District of California
Barbara Clarke McCurdy (Admitted Pro Hac Vice) firstname.lastname@example.org Naveen Modi (Admitted Pro Hac Vice) email@example.com Srikala P. Atluri (Admitted Pro Hac Vice) firstname.lastname@example.org FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 901 New York Avenue, N.W. Washington, D.C. 20001 Telephone: (202) 408-4000 Facsimile: (202) 408-4400 Tina E. Hulse (CA Bar No. 232936) 8 email@example.com FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 3300 Hillview Avenue Palo Alto, California 94304-1203 Telephone: (650) 849-660 Facsimile: (650) 849-6666 Attorneys for Defendant Rambus Inc.
STIPULATION RE: CASE SCHEDULE; SUPPORTING DECLARATION OF TINA E. HULSE; [PROPOSED] ORDER
Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiff International Business Machines Corporation ("IBM") and Defendant Rambus Inc. ("Rambus"), through their respective counsel of 3 record, respectfully request, and with the Court's permission, stipulate to a four-week extension of 4 the current case schedule to allow the parties to effectively discuss settlement. More specifically, 5 with the Court's permission, the parties hereby stipulate that the current schedule set forth in the January 18, 2011, Civil Minute Order [Dkt. 38] be modified as follows:
EVENT CURRENT SCHEDULE PROPOSED DATE
Rambus shall file opening June 24, 2011 July 22, 2011 9 summary judgment motion IBM shall file opposition and July 8, 2011 August 5, 2011 cross-motion for summary 12 judgment Rambus shall file reply and July 22, 2011 August 19, 2011 14 opposition to cross-motion for summary judgment IBM shall file reply in support July 29, 2011 August 26, 2011 16 of cross-motion for summary judgment 17 Hearing on Cross-Dispositive August 26, 2011 September 23, 2011, or any Motions later date, subject to the 19 convenience of the Court's calendar
By her signature below, counsel for Defendant attests that counsel for
Plaintiff concurs in the
filing of this stipulation.
SUPPORTING DECLARATION OF TINA E. HULSE
I, TINA E. HULSE, declare as follows: 3
1. I am an associate at Finnegan, Henderson, Farabow, Garrett &
Dunner, L.L.P., counsel
for Defendant Rambus Inc. ("Rambus"). I submit this declaration in
support of the parties' 5
Stipulation Regarding Case Schedule. I make this declaration of my own
personal knowledge and 6 will competently testify thereto if called
upon to do so.
2. On January 18, 2011, the Court entered a Civil Minute Order
("Order") [Dkt. 38]
following the initial Case Management Conference. The Order set
forth a briefing schedule for 9 cross-motions for summary judgment.
The Order also set the hearing on cross-dispositive motions 10 for
August 26, 2011, at 9:00 a.m. 11
3. The parties, both the respective corporate representatives and
outside counsel, have been
actively discussing resolution of this case. Accordingly, the
parties have met and conferred and 13 agree that continuing the case
schedule for four weeks will facilitate these settlement discussions.
4. There have been no previous time modifications of the case schedule set forth in the Order. Otherwise, the only time modification in this case was to change the Case Management Conference from December 3, 2010, to January 14, 2011, to coincide with the hearing on Rambus's 17 motion to dismiss. See Dkt. 30.
5. The requested modification in the current case schedule will not affect any other pre-trial 19 deadlines, as the pre-trial schedule has not yet been entered in this case.
I declare under penalty of perjury under the laws of the United States
that the foregoing is
true and correct, and this declaration was executed this 14th day
of April, 2011.22
Tina E. Hulse
Tina E. Hulse
PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated: April __, 2011
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