UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO)
November 28, 2011
ADOBE SYSTEMS INCORPORATED,
MARYAM GHERMAZIAN, ET AL. DEFENDANTS.
The opinion of the court was delivered by: Hon. Jeffrey S. White
STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND [PROPOSED] ORDER AS MODIFIED HEREIN
Date: December 2, 2011
Time: 1:30 p.m.
ALL RELATED CLAIMS
PLAINTIFF Adobe Systems Incorporated ("Adobe"), by and through its counsel of record, and Defendants Maryam Ghermazian, an individual and d/b/a www.saveintheusa.com, and Technology One Online d/b/a Tech 1, Technology 1 and Technology One Corporation (collectively "Defendants"), by and through their counsel of record, hereby stipulate and request as follows:
WHEREAS Adobe filed its complaint on or about August 8, 2011;
WHEREAS counsel for Defendants first contacted counsel for Adobe on or about November 10, 2011, regarding her recent retention by Defendants;
WHEREAS counsel for Defendants has indicated that she will accept service for Defendants;
WHEREAS an Acknowledgment of Service is being sent to counsel for Defendants on or about November 10, 2011;
WHEREAS counsel for Defendants has not yet reviewed the Complaint and will need sufficient time to prepare a response;
WHEREAS the return of the Acknowledgment will give Defendants until January 9, 2012, to respond to the Complaint;
WHEREAS Defendant Morris Cohen a/k/a Morris Kohanian, an individual and d/b/a www.saveintheusa.com ("Cohen"), remains unserved;
WHEREAS Adobe has until December 6, 2011, to serve Defendant Cohen;
WHEREAS briefly continuing the Case Management Conference and all corresponding deadlines will provide the Parties with additional time to possibly resolve this matter informally or, alternatively, better brief the Court regarding the Parties' positions and any outstanding issues; and
WHEREAS Defendants by agreeing to a continuation of the case management conference do not intend to waive, and expressly reserve any and all rights or defenses, including those based on subject matter jurisdiction, personal jurisdiction or venue.
March 16, 2012 at 1:30 p.m. A joint case management statement is due on March 9, 2012. If Plaintiff requires additional time to serve Defendant Cohen, they should file the appropriate request with the Court.
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