The opinion of the court was delivered by: Jeremy Fogel United States District Judge
STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND [PROPOSED] ORDER JSW
Date: September 30, 2011 Time: 10:30 a.m. Court: Hon. Jeremy Fogel
PLAINTIFF Adobe Systems Incorporated ("Plaintiff") and Defendants Adam Childers, an individual, and SoftwareMedia.com, Inc. (collectively "Defendants"), by and through their respective counsel of record, hereby stipulate and agree as follows:
WHEREAS the Parties conducted a settlement conference with Magistrate Judge Lloyd on or about July 29, 2011;
WHEREAS the Parties reached a settlement in principle at that time; 8 WHEREAS the Parties are currently exchanging settlement documents and are very close 9 to finalizing settlement;
WHEREAS certain disclosures are required from Defendant in order to finalize settlement;
WHEREAS Defendant has been compiling the required information, but it has taken longer than expected, and he anticipates providing the disclosures no later than September 30, 2011;
WHEREAS both counsel for Plaintiff and counsel for Defendants are located in Southern California such that travel to the Case Management Conference would incur significant additional expenses to both sides;
WHEREAS continuing the Case Management Conference will provide the Parties with additional time to finalize settlement and file the appropriate documents to dismiss this action in its entirety; and
NOW, THEREFORE, Plaintiff and Defendants stipulate and request the Court continue the Case Management Conference for twenty-one (21) days, or not earlier than October 21, 2011.
DATED: September 23, 2011 J. Andrew Coombs, A Professional Corp. By: ___/s Nicole L. Drey_______________________ J. Andrew Coombs Nicole L. Drey Attorneys for Plaintiff Adobe Systems Incorporated DATED: September 23, 2011 McCurdy & Leibl, LLP By: ___/s Reagan Elizabeth Boyce_______________ John D. McCurdy Reagan Elizabeth Boyce Attorney for Defendants Adam Childers and SoftwareMedia.com, Inc.
PURSUANT TO REQUEST, IT IS SO ...