UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
November 5, 2012
HARDLINE DESIGN LLC,
EDGE INTERNATIONAL, LLC; AND, B8
CONCEPT LTD., DEFENDANTS.
The opinion of the court was delivered by: Judge: The Honorable Richard Seeborg
JOINT STIPULATION AND [PROPOSED] ORDER
Trial Date: N/A
Action Filed: July 30, 2012
AND ALL RELATED CROSS CLAIMS
JOINT STIPULATION AND [PROPOSED] ORDER;
Plaintiff and Counterclaim Defendant HARDLINE DESIGN LLC ("Hardline") and Defendant and Counterclaim Plaintiff EDGE INTENATIONAL, LLC ("Edge") respectfully 4 file this joint stipulation and proposed order. The following items are currently on calendar 5 before this Court (in chronological order):
(1) Response to Edge's motion for summary judgment (Docket No. 16), due November 7, 2012;
(2) Joint Case Management Statement and Rule 26(a)(1) disclosures, due November 8, 2012;
(3) Reply to Edge's motion for summary judgment (Docket No. 16), due November 14, 2012;
(4) Case Management Conference and hearing on Hardline's motion to dismiss (Docket No. 13), on November 15, 2012; and
(5) Hearing on Edge's motion for summary judgment (Docket No. 16), on November 29, 2012.
Subject to the Court's approval, Hardline and Edge have agreed to an immediate and temporary 45-day stay of this case, beginning from the date of the signed Court order.
Hardline and Edge have stipulated to the following:
(1) Hardline shall send a demand of notice of arbitration pursuant to AAA rules to
B8 Concept Limited, by sending such notice to:
B8 Concept Ltd. Rm A 15/F
Hillier Commercial Building 65-67 Bonham Strand East Sheung Wan, Hong Kong
and to email@example.com.
With a cc to Joshua Kirsch at firstname.lastname@example.org
(2) Hardline shall send a demand of notice of arbitration pursuant to AAA rules to Edge International, LLC via its counsel of record, Joshua Kirsch, by regular mail at GIBSON ROBB & LINDH, LLP, 201 Mission St., Suite 2700, San Francisco, CA 94105 and email at !
email@example.com. It is the intent of the parties hereto that all three contracts in dispute
shall be subject to a single, binding arbitration.
(3) In the event that B8 Concept Limited responds to the demand and submits to binding arbitration, Edge and Hardline shall stipulate to extend the 45-day stay of this Court action indefinitely to permit the arbitration to proceed. (4) In the event that the 45-day stay expires without further stipulation, all oppositions and replies to be filed in response to the above-listed motions, to the extent such oppositions and replies have not yet been filed, will be filed pursuant to Local Rule 7-3 or other agreement of the parties.
PURSUANT TO STIPULATION, IT IS SO ORDERED:
The Honorable Richard Seeborg United States District Court Judge
Dated: November 2, 2012 Respectfully submitted, 2 By /s/ Inder Comar 3 D. Inder Comar COMAR LAW 4 901 Mission Street, Ste. 105 San Francisco, CA 94103 5 Telephone: (415) 640-5856 6 Facsimile: (415) 513-0445 Email: firstname.lastname@example.org 7 Attorney for Plaintiff / Counterclaim 8 Defendant HARDLINE DESIGN LLC 9 10 By /s/ Joshua Kirsch 11 Joshua Kirsch GIBSON ROBB & LINDH LLP 12 201 Mission Street, Ste. 2700 13 San Francisco, CA 94105 Telephone: (415) 348-6000 14 Facsimile: (415) 348-6001 Email: email@example.com Attorney for Defendant / Counterclaim Plaintiff 17 EDGE INTERNATIONAL, LLC
DECLARATION OF CONSENT
Pursuant to Local Rule 5-1 regarding signatures, I attest under penalty of perjury that concurrence in the filing of this document has been obtained from all counsel for all parties.
/s/ Inder Comar
D. Inder Comar
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