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Cypress Semiconductor Corporation, A Delaware Corporation v. Deutsche Bank Securities Inc.

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION


November 29, 2011

CYPRESS SEMICONDUCTOR CORPORATION, A DELAWARE CORPORATION,
PLAINTIFF,
v.
DEUTSCHE BANK SECURITIES INC., A DELAWARE CORPORATION,
DEUTSCHE BANK ALEX. BROWN, A DIVISION OF DEUTSCHE BANK SECURITIES INC., AND
DEUTSCHE BANK AG,
DEFENDANTS.

The opinion of the court was delivered by: The Honorable Claudia Wilken United States District Judge

William J. Goines (SBN 61290) GREENBERG TRAURIG, LLP 1900 University Avenue, 5th Floor East Palo Alto, CA 94303 Telephone: (650) 328-8500 Facsimile: (650) 328-8508 Email: goinesw@gtlaw.com Attorneys for Defendants

STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS TO RESPOND TO COMPLAINT AND ADJOURNING MANAGEMENT CONFERENCE

CASE

(Case Assigned to Hon. Claudia Wilken)

Plaintiff and Defendants, by and through their respective undersigned counsel, stipulate and 19 agree as follows: 20 WHEREAS, on June 2, 2011, the Court So Ordered the parties' initial stipulation 21 extending the time for Defendants to respond to the Complaint in this action to July 11, 2011; and 22 WHEREAS, on July 8, 2011, the Court So Ordered the parties' second stipulation 23 extending the time for Defendants to respond to the Complaint in this action through and including 24 August 24, 2011; and 25

WHEREAS, on September 1, 2011, the Court So Ordered the parties' third stipulation 26 extending the time for Defendants to respond to the Complaint in this action through and including 27 September 23, 2011; and 28 2 extending the time for Defendants to respond to the Complaint in this action through and including 3

WHEREAS, on October 25, 2011, the Court So Ordered the parties' fifth stipulation 5 extending the time for Defendants to respond to the Complaint in this action through and including 6

WHEREAS the parties have now reached agreement on the terms of a settlement and 8 anticipate filing a stipulation of dismissal within fourteen (14) days; and 9 10 an additional 30-day extension of the time for all Defendants to move against, answer or respond 11 to the Complaint (through and including December 23, 2011), by which time the parties anticipate 12 having filed a stipulation of dismissal; and 13

WHEREAS, on September 29, 2011, the Court So Ordered the parties' fourth stipulation October 24, 2011; and 4 November 23, 2011; and 7

WHEREAS, accordingly, Defendants have met and conferred with Plaintiff and requested

WHEREAS, Plaintiff has consented to Defendants' request; and

WHEREAS the Court had scheduled an initial Case Management Conference for November 29, 2011 at 2:00 p.m.; and 16

WHEREAS the parties believe that there will be no need for a Case Management Conference because a stipulation of dismissal will be filed within fourteen (14) days; 18 19 respective counsel, and subject to Court approval, that the time for all Defendants to move against, 20 answer or respond to the Complaint shall be extended from November 23, 2011 through and 21 including December 23, 2011; and 22

IT IS HEREBY STIPULATED, by and between Plaintiff and Defendants, through their IT IS FURTHER STIPULATED that the Case Management Conference scheduled for November 29, 2011 at 2:00 p.m. shall be adjourned. 24

In accordance with General Order 45 of the United States District Court for the Northern District of California, I attest that concurrence in the filing of this document has been obtained 26 from the undersigned counsel. 27 28

PURSUANT TO STIPULATION, IT IS SO ORDERED.

DATED: ________________, 2011

ATTESTATION CLAUSE

I, William J. Goines, am the ECF User whose ID and password are being used to file this STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS TO 4 RESPOND TO COMPLAINT AND ADJOURNING NOVEMBER 29, 2011 CASE 5 MANAGEMENT CONFERENCE. In compliance with General Order 45, X.B., I hereby attest 6 that Philip J. Wang has concurred in this filing. 7 8 Date: November 23, 2011 GREENBERG TRAURIG, LLP By: /s/ William J. Goines

20111129

© 1992-2011 VersusLaw Inc.



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