The opinion of the court was delivered by: The Honorable Jeffrey White United States District Judge
STIPULATION AND [PROPOSED] )ORDER PURSUANT TO CIVIL LOCAL )RULE 6-2 TO EXTEND TIME FOR )PLAINTIFF AND DEFENDANTS TO )SUBMIT THEIR JOINT CLAIM )CONSTRUCTION AND PRE-HEARING )STATEMENT IN ACCORDANCE WITH PATENT LOCAL RULE 4-3
Pursuant to Civil L.R. 6-2, Plaintiff Innovus Prime LLC ("INNOVUS") and Defendants LG Electronics Inc. et al. (collectively, "LG") hereby stipulate to extend the time for INNOVOUS 4 and LG to submit their Joint Claim Construction and Pre-Hearing Statement in accordance with 5 Patent Local Rules 4-3. 6
Scheduling conflicts in other matters, as well as unforeseeable issues, including a power 7 outage in the offices of INNOVUS's attorney that disrupted his operations, have hampered the 8 parties' efforts to finalize the Joint Claim Construction and Pre-Hearing Statement, which is 9 presently due. 10 Accordingly, the parties wish to extend the time for filing their Joint Claim Construction 11 and Pre-Hearing Statement from September 10, 2012 to September 14, 2012. The requested time 12 modification will have no effect on the remaining schedule of this case. 13
This is INNOVUS and LG's second request for a modification of the date for filing the 14 parties' Joint Claim Construction and Pre-Hearing Statement under Patent L.R 4-3. 15 Accordingly, it is hereby stipulated and agreed that INNOVUS and Defendants LG be 16 allowed to submit their Joint Claim Construction and Pre-Hearing Statement on or before 17 September 14, 2012.
Respectfully submitted, DATED: September 10, 2012 By: /s/ John W. Carpenter 20 JOHN W. CARPENTER (Cal. Bar No. 221708) Law Offices of John W. Carpenter LLC 12 Metairie Court Metairie, LA 70001-3032 Telephone: 1-415-577-0698 Facsimile: 1-866-410-6248 Email: firstname.lastname@example.org Attorneys for Plaintiff Innovus Prime LLC DATED: September 10, 2012 By: /s/ Nicholas A. Brown 27 Nicholas A. Brown (CA SBN 198210) email@example.com GREENBERG TRAURIG LLP 4 Embarcadero Center, Suite 3000 San Francisco, CA 94111 Telephone: 415.655.1300 Facsimile: 415.707.2010 Richard D. Harris firstname.lastname@example.org Jeffrey G. Mote email@example.com Kevin J. O'Shea firstname.lastname@example.org GREENBERG TRAURIG LLP 77 West Wacker Drive Chicago, IL 60601 Telephone: 312.456.8400 Facsimile: 312.456.8435 Attorneys for Defendants LG Electronics, Inc. and LG Electronics U.S.A., Inc. ATTESTATION
I, Nicholas A. Brown, am the ECF User whose identification and password are being used
15 to file this Stipulation to: Extend Time for Plaintiff and Defendants to Submit their Joint Claim 16
Construction and Pre-Hearing Statement in Accordance with Patent Local Rule 4-3. I hereby 17 attest that Plaintiff's counsel, John W. Carpenter, has concurred in this filing. 18 19
PURSUANT TO STIPULATION AND UPON GOOD CAUSE ...