The opinion of the court was delivered by: Hon. Susan Illston United States District Judge
MORGAN, LEWIS & BOCKIUS LLP KENT M. ROGER, State Bar No, 95987 2 HERMAN J. HOYING, State Bar No. 257495 JENNIFER L. CALVERT, State Bar No. 258018 3 One Market, Spear Street Tower San Francisco, CA 94105-1126 4 Tel: 415.442.1000 Fax: 415.442.1001 5 kroger@morganlewis.com hhoying@morganlewis.com 6 jennifer.calvert@morganlewis.com 7 Attorneys for Defendants HITACHI, LTD., HITACHI DISPLAYS, LTD., 8 HITACHI ELECTRONIC DEVICES (USA), INC. 9 10
This Document Relates to Individual
Master File No. 3:07-md-1827
STIPULATION AND [PROPOSED] ORDER REGARDING TIME TO RESPOND TO AMENDED COMPLAINT
WHEREAS plaintiff State of Oregon ("Oregon") filed the above captioned lawsuit on August 10, 2010; 3
WHEREAS Oregon filed a first amended complaint on April 15, 2011 ("Amended Complaint"); 5
WHEREAS Defendants Hitachi Displays, Ltd., Hitachi Electronic Devices (USA), Inc. 6 7 and Hitachi, Ltd. (collectively, the "Hitachi Defendants") and Defendants Chi Mei Corporation, Chi Mei Innolux Corporation, CMO Japan Co., Ltd., and Chi Mei Optoelectronic USA, Inc. 9 (collectively, the "Chi Mei Defendants") jointly filed with other defendants a motion to dismiss 10 Count III in its entirety and Count IV to the extent it seeks "disgorgement of profits" as a remedy 11 on June 6, 2011; 12
WHEREAS the Court denied Defendants' joint motion to dismiss Counts III and IV of the Amended Complaint on July 12, 2011;
WHEREAS all defendants, including the Hitachi Defendants and Chi Mei Defendants, entered into a stipulation with Oregon on July 21, 2011 that Defendants' deadline to answer the 17 Amended Complaint was August 12, 2011; 18
WHEREAS on July 21, 2011, the Court entered an order extending Defendants' deadline 19 to answer the Amended Complaint until August 12, 2011; 20
WHEREAS the Hitachi Defendants and Chi Mei Defendants entered into a stipulation with Oregon on August 11, 2011 that the Hitachi Defendants' and Chi Mei Defendants' deadline to answer the Amended Complaint is September 12, 2011; 24
WHEREAS on August 24, 2011, the Court entered an order extending the Hitachi Defendants' and Chi Mei Defendants' deadline to answer the Amended Complaint until 26 September 12, 2011;
WHEREAS the Hitachi Defendants and Chi Mei Defendants entered into a stipulation 2 with Oregon on September 9, 2011 that the Hitachi Defendants' and Chi Mei Defendants' 3 deadline to answer the Amended Complaint is September 26, 2011; 4
WHEREAS on September 13, 2011, the Court entered an order extending the Hitachi Defendants' and Chi Mei Defendants' deadline to answer the Amended Complaint until 6 7 September 26, 2011;
WHEREAS the Hitachi Defendants and Chi Mei Defendants entered into a stipulation 9 with Oregon on September 23, 2011 that the Hitachi Defendants' and Chi Mei Defendants' 10 deadline to ...