James T. Hultquist (pro hac vice), Khurram N. Gore (pro hac vice), Adrian Shin (CA State Bar No. 256960), REED SMITH LLP PITTMAN LLP, San Francisco, CA, Attorneys for Defendant, GROUPON, INC.
James F. Valentine, CA SB# 149269, James C. Pistorino, CA SB# 226496 PERKINS COIE LLP, Palo Alto, Attorneys for Defendant GOOGLE, INC.
Jenna F. Karadbil, California State Bar No. 213574 PILLSBURY WINTHROP SHAW PITTMAN LLP New York, New York.
Callie A. Bjurstrom, California State Bar No. 137816 PILLSBURY WINTHROP SHAW PITTMAN LLP, San Diego, California Attorneys for Plaintiff MOUNT HAMILTON PARTNERS, LLC
STIPULATION AND [PROPOSED] ORDER CONTINUING FURTHER CASE MANAGEMENT CONFERENCE [Civ. L.R. 6-2 & 7-12].
SUSAN ILLSTON, District Judge.
Pursuant to Local Rules 6-2 and 7-12, Plaintiff Mount Hamilton Partners, LLC ("MHP" or "Plaintiff") and Defendants Groupon, Inc. ("Groupon") and Google, Inc. ("Google") (collectively, "Defendants"), by and through their respective undersigned counsel, hereby jointly move the Court for an order continuing the scheduled date for a Further Case Management Conference, for the following reasons:
1. Pursuant to this Court's September 25, 2012 Case Management Conference Order (Dkt. No. 47), the parties are required to participate in a Further Case Management Conference on May 10, 2013.
2. On May 3, 2013, this Court continued the Claim Construction Tutorial and Claim Construction Hearing to June 20, 2013; and June 26, 2013, respectively.
3. Accordingly, because it is the belief of the parties that holding a Further Case Management Conference after the date of the Claim Construction Hearing in this case will be more efficient for this Court and the parties, the parties hereby stipulate to and request the Court to continue the Further Case Management Conference from May 10 to August 23, 2013 at 3:00 p.m. or such other date and time that is agreeable with the Court's calendar. The requested continuance does not affect any other deadline ordered by the Court.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
DECLARATION OF KHURRAM N. GORE IN SUPPORT OF STIPULATION AND [PROPOSED] ORDER CONTINUING FURTHER CASE MANAGEMENT CONFERENCE
Civ. L.R. 6-2 & 7-12]
I, Khurram Nasir Gore, declare:
1. I am an associate with Reed Smith LLP, counsel for Defendants Groupon, Inc. ("Groupon"), in the above-captioned action. The contents of this declaration are based upon my personal knowledge and are true and correct to the best of my knowledge and ...