UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO)
August 1, 2012
ADOBE SYSTEMS INCORPORATED,
MATTHEW RENE, ET AL., DEFENDANTS.
The opinion of the court was delivered by: Charles R. Breyer Judge
J. Andrew Coombs (SBN 123881) email@example.com Nicole L. Drey (SBN 250235) firstname.lastname@example.org J. Andrew Coombs, A P. C. 517 East Wilson Avenue, Suite 202 3 Glendale, California 91206 Telephone: (818) 500-3200 4 5 Facsimile: (818) 300-3201 Attorneys for Plaintiff Adobe Systems Incorporated 6 7 8 Andrew D. Winghart (SBN 225099) email@example.com Winghart Law Group 495 Seaport Court, Suite 104 9 Redwood City, California 94063 Telephone: (510) 593-8546 10 11 Facsimile: (866) 941-8593 Attorneys for Defendants Francis Pierre and Futursoft Solutions, Inc., erroneously sued 12 as Francis Pierre, an individual and d/b/a www.futursoftsolutions.com, Isaac Abady 13 and Computer Software Plus, Inc., erroneously sued as Isaac Abady a/k/a Ike 14 Abady a/k/a Ike Abadi a/k/a Ike Ababi, an individual and d/b/a 15 www.topdealscenter.com and Top Deals Center
STIPULATION TO EXTEND ADR DEADLINE AND CONTINUE FURTHER CASE MANAGEMENT
CONFERENCE AND [PROPOSED] ORDER
Current ADR Deadline: July 30, 2012 CMC: August 10, 2012 Time: 8:30 a.m. ) Court: Hon. Charles R. Breyer
PLAINTIFF Adobe Systems Incorporated ("Adobe"), by and through its counsel of record, and Defendants Francis Pierre and Futursoft Solutions, Inc., erroneously sued as Francis Pierre, an individual and d/b/a www.futursoftsolutions.com, Isaac Abady and Computer Software Plus, Inc., erroneously sued as Isaac Abady a/k/a Ike Abady a/k/a Ike Abadi a/k/a Ike Ababi, an individual and d/b/a www.topdealscenter.com and Top Deals Center (collectively "Defendants"), by and through their counsel of record, hereby stipulate and request as follows:
WHEREAS a Case Management Conference was held on April 20, 2012;
WHEREAS the Court ordered a Further Case Management Conference on June 8, 2012, to occur after mediation had taken place;
WHEREAS the Parties had scheduled mediation to take place on July 17, 2012;
WHEREAS the Further Case Management Conference was then continued until August 10, 2012, to occur after the mediation;
WHEREAS Defendants' counsel informed Plaintiff's counsel and the mediators on July 9, 2012, regarding a family emergency that would prevent him from attending the mediation;
WHEREAS Defendants' counsel is a solo practitioner who did not have any associate or co-counsel who could represent Defendants in his stead;
WHEREAS Plaintiff and the mediators consented to the continuance of the mediation due to Defendants' counsel's extraordinary circumstances;
WHEREAS Defendants' counsel has been out of the office for the past few weeks due to said family emergency;
WHEREAS the Parties are now currently attempting to re-schedule the mediation for a time in August or September;
WHEREAS extending the ADR deadline by sixty (60) days and continuing the Case Management Conference until after the mediation will allow the Parties sufficient time to attempt to resolve this matter without further intervention of the Court as well as allow sufficient time for Defendants' counsel to address his overdue commitments from his extended absence; and
WHEREAS no other Court deadlines will be affected by an extension of the ADR deadline or continuation of the Case Management Conference.
NOW, THEREFORE, Adobe and Defendants stipulate and respectfully request the Court extend the ADR deadline to September 30, 2012, and continue the Joint Case Management Conference until October 19, 2012, or a date thereafter acceptable with the Court.
IT IS SO STIPULATED.
PURSUANT TO REQUEST, IT IS HEREBY ORDERED that the ADR Deadline is extended to
. It is further ordered that September 30, 2012 the Case Management Conference shall be continued to ______________________________.
October 19, 2012 at 8:30 a.m.
IT SO ORDERED
Hon. Charles R. Breyer UNITED STATES DISTRICT JUDGE
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