UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO)
April 19, 2011
ADOBE SYSTEMS INCORPORATED, PLAINTIFF,
RENEE NORWOOD, ET AL.,
The opinion of the court was delivered by: Hon. Susan Illston United States District Judge
J. Andrew Coombs (SBN 123881) firstname.lastname@example.org Nicole L. Drey (SBN 250235) email@example.com J. Andrew Coombs, A P. C. 517 East Wilson Avenue, Suite 202 Glendale, California 91206 Telephone: (818) 500-3200 Facsimile: (818) 300-3201 Attorneys for Plaintiff and Counter-Defendant Adobe Systems Incorporated and Third-Party Defendant Software & Information Industry Association (erroneously identified as Counter-Defendant) Michael L. Rodenbaugh (SBN 179059) firstname.lastname@example.org Rodenbaugh Law 548 Market Street San Francisco, California 94104 Telephone: (415) 738-8087 Facsimile: (415) 738-8087 Attorneys for Defendant, Counter-Claimant and Third-Party Plaintiff Renee Norwood
JOINT STIPULATION RE CONTINUANCE OF HEARING DATE ON PENDING MOTION TO DISMISS AMENDED COUNTERCLAIMS ALL RELATED CLAIMS
Plaintiff and Counter-Defendant Adobe Systems Incorporated ("Adobe"), Third-Party Defendant Software & Information Industry Association ("SIIA"), and Defendant and Counter- Claimant Renee Norwood ("Norwood") (collectively the "Parties"), by and through their respective counsel of record, hereby stipulate and agree as follows:
WHEREAS Norwood filed her Amended Counterclaims on or about March 18, 2011;
WHEREAS Adobe and the SIIA filed their Motion to Dismiss the Amended Counterclaims ("Motion") on or about April 8, 2011;
WHEREAS the Parties stipulate that any delay in filing the Motion has not caused prejudice to Norwood and that Norwood waives any objections to the timeliness of the Motion, in the event this stipulation is entered by the Court;
WHEREAS the hearing on the Motion is currently set for May 13, 2011;
WHEREAS counsel for Norwood has a familial obligation on May 13, 2011, such that he cannot attend the hearing;
WHEREAS counsel for Norwood is currently preparing a motion to withdraw as counsel due to Norwood's unresponsiveness and lack of payment;
WHEREAS, if Norwood's current counsel is granted leave to withdraw as counsel, Norwood will need sufficient time to retain new counsel and/or prepare an opposition to the Motion;
WHEREAS, alternatively, should counsel's motion to withdraw not be granted, counsel will need sufficient time to prepare an opposition to the Motion and is not available for hearing prior to July 8, 2011;
WHEREAS the requested continuance will not affect any current Court deadlines; and
NOW, THEREFORE, Adobe, the SIIA, and Norwood stipulate and request the hearing on Adobe and the SIIA's Motion be continued until July 8, 2011, or a date thereafter acceptable with the Court, with all briefing dates adjusted accordingly.
IT IS SO STIPULATED:
PURSUANT TO REQUEST, IT IS SO ORDERED.
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