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Amc Technology, L.L.C v. Cisco Systems

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION


September 23, 2011

AMC TECHNOLOGY, L.L.C.,
PLAINTIFF,
v.
CISCO SYSTEMS, INC.,
DEFENDANT.

The opinion of the court was delivered by: Honorable Paul S. Grewal United States Magistrate Judge

STEPHEN E. TAYLOR (SBN 58452) JEFFREY E. FAUCETTE (SBN 193066) 2 TAYLOR & COMPANY LAW OFFICES, LLP One Ferry Building, Suite 355 3 San Francisco, California 94111 Telephone: (415) 788-8200 4 Facsimile: (415) 788-8208 E-mail: staylor@tcolaw.com 5 E-mail: jfaucette@tcolaw.com 6 R. WEBB MOORE (Admitted Pro Hac Vice) FRANKLIN R. CRAGLE, III (Admitted Pro Hac Vice) 7 HIRSCHLER FLEISCHER A PROFESSIONAL CORPORATION 8 The Edgeworth Building 2100 East Cary Street 9 Post Office Box 500 Telephone: (804) 771-9561 10 Facsimile: (804) 644-0957 E-mail: wmoore@hf-law.com 11 E-mail: fcragle@hf-law.com 12 Attorneys for Plaintiff AMC TECHNOLOGY, L.L.C. 13 14

STIPULATION AND [PROPOSED] ORDER REGARDING BRIEFING SCHEDULE AND INITIAL CASE MANAGEMENT CONFERENCE

26(f) of the Federal Rules of Civil Procedure. Subject to the Court's approval, the Parties 4

WHEREAS, on September 2, 2011 counsel for AMC and Cisco conducted a Rule 26(f)

6 conference, at which the Parties discussed the nature and basis of their respective claims and 7 defenses; 8

to AMC's Complaint; 10

Plaintiff AMC Technology, L.L.C. ("AMC") and Defendant Cisco Systems, Inc. ("Cisco")

(collectively "the Parties") have conferred, by and through their counsel, in accordance with Rule 3

HEREBY STIPULATE AS FOLLOWS: 5

WHEREAS, the Parties discussed Cisco's intention to file a Motion to Dismiss in response

WHEREAS, on September 12, 2011, Cisco timely filed its Motion to Dismiss AMC's Complaint; its First Amended Complaint pursuant to Rule 15 of the Federal Rules of Civil Procedure on or 14 before October 3, 2011 (the "First Amended Complaint");

WHEREAS, the Parties have jointly agreed that AMC shall serve and either file or lodge

WHEREAS, the Parties have further agreed that Cisco's will respond to the First Amended Complaint on or before October 24, 2011 (the "Cisco Response"); 18 a Motion to Dismiss the First Amended Complaint), the Parties agree AMC's responsive papers 19 shall be served and either filed or lodged on or before November 14, 2011 (the "AMC 20

WHEREAS, the Parties agree that any reply by Cisco to the AMC Opposition shall be served and either filed or lodged on or before November 28, 2011; to Dismiss the First Amended Complaint, the hearing for such motion shall be on December 13, 2011, or such other later date as may be available on the Court's calendar for the hearing of the 26 motion; 27

WHEREAS, the Parties further agree that the Initial Case Management Conference in this case shall be continued to December 13, 2011, or such other later date as may be convenient for

WHEREAS, if the Cisco Response takes the form of anything other than an Answer (e.g., Opposition");

WHEREAS, the Parties further agree that if the Cisco Response takes the form of a Motion the Court, and; 2

WHEREAS, the Parties agree that, in anticipation of the Initial Case Management Conference, the parties shall submit their discovery plan and stipulations pursuant to Rule 26(f)(2) 4 on or before November 29, 2011. 5

By and through counsel and subject to the Court's approval,

IT IS SO STIPULATED. 7

Dated: September 16, 2011 Respectfully submitted,

GENERAL ORDER ATTESTATION

I, Stephen E. Taylor, am the ECF user whose ID and password are being used to file the Stipulation and [Proposed] Order Regarding Briefing Schedule and Initial Case Management 25 Conference. In compliance with General Order 45, X.B., I hereby attest that each listed counsel 4 above has concurred in this filing. 5

Dated: September 16, 2011 /s/ Stephen E. Taylor

PROPOSED ORDER

Pursuant to the above Stipulation, and good cause appearing therefore, IT IS SO ORDERED.

DATED: _6HSWHPEHU

20110923

© 1992-2011 VersusLaw Inc.



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