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Clover Sites, Inc., A California Corporation v. Clover Network
September 26, 2011
CLOVER SITES, INC., A CALIFORNIA CORPORATION, PLAINTIFF,
CLOVER NETWORK, INC., A DELAWARE
The opinion of the court was delivered by: Judge: Honorable Jeffrey S. White
M USICK, P EELER & GARRETT LLP ATTORNEYS AT LAW 225 BROADWAY, SUITE 1900 SAN DIEGO, CALIFORNIA 92101-5028 TELEPHONE: 619-525-2553 FACSIMILE 619-231-1234 Whit Bivens (State Bar No. 190727) firstname.lastname@example.org Catherine M. Lee (State Bar No. 197197) email@example.com Attorneys for PLAINTIFF CLOVER SITES, INC., a California corporation
STIPULATION AND [PROPOSED] ORDER EXTENDING (1) TIME FOR DEFENDANT'S TO RESPOND TO AMENDED COMPLAINT; AND (2) BRIEFING SCHEDULE ON PLAINTIFF'S MOTION FOR PRELIMINARY
Plaintiff Clover Sites, Inc. and Defendant Clover Network, Inc.,
through their respective
counsel, hereby stipulate to:
1. extend the time for Defendant to respond to Plaintiff's amended complaint from October 11, 2011 to October 20, 2011; and
2. extend the time for Defendant to file its opposition to
Plaintiff's motion for
preliminary injunction from September 29, 2011 to October 20, 2011.
The parties respectfully submit that there is good cause for this
brief extension of the
schedule for responding to the amended complaint and preliminary
injunction motion. The parties have exchanged settlement
communications and agreed to engage in further settlement
discussions. The parties seek this additional time to continue to
explore whether an early
settlement may be achieved, which would serve the interests of
judicial economy and the parties.
The parties wish to devote the next two weeks to pursuing settlement in good faith, but will be significantly impeded in their ability to do so under the current schedule, which would require them to devote their efforts during this time to preparing extensive filings relating to the preliminary injunction motion. Since the hearing on the preliminary injunction motion is not set until December 9, 2011, the parties' proposed schedule would still provide the Court with over a month to review motion papers in advance of the hearing.
Based on the foregoing, the parties respectfully submit that good cause exists for the extension proposed above.
The Court has received and considered the above stipulation of the
parties. The Court
finds that good cause exists to grant the requested extension.
IT IS HEREBY ORDERED that:
The time for Defendant to respond to Plaintiff's amended complaint and motion for preliminary injunction shall be extended to October 20, 2011;
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