CIRCLE CLICK MEDIA LLC, a California limited liability company; METRO TALENT, LLC, a California limited liability company; and CTNY INSURANCE GROUP LLC, a Connecticut limited liability company, on behalf of themselves and others similarly situated, Plaintiffs,
REGUS MANAGEMENT GROUP, LLC, a Delaware limited liability company; REGUS BUSINESS CENTRE LLC, a Delaware limited liability company; REGUS PLC, a Jersey, Channel Islands, public limited company; HQ GLOBAL WORKPLACES LLC, a Delaware limited liability company; and DOES 1-50, Defendants.
K. Lee Marshall, California Bar No. 277092, Meryl Macklin, California Bar No. 115053, Daniel Thomas Rockey, California Bar No. 178604, Stephanie Blazewicz, California Bar No. 240359, Bahareh Wullschleger, California Bar No. 258903, BRYAN CAVE LLP, San Francisco, CA, Attorneys for Defendants, REGUS MANAGEMENT GROUP, LLC, REGUS BUSINESS CENTRE, LLC, REGUS plc, and HQ GLOBAL WORKPLACES LLC.
Ali Aalaei, California Bar No. 254713, Bo Zeng, California Bar No. 281626 ARI LAW, P.C. San Francisco, CA, Joseph A. Garofolo, State Bar No. 214614 Kelly A. Weekes, State Bar No. 269959, GAROFOLO LAW GROUP, P.C., San Francisco, CA, Attorneys for Plaintiffs, CIRCLE CLICK MEDIA LLC, METRO TALENT LLC, and CTNY INSURANCE GROUP LLC.
STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE
SAMUEL CONTI, Sr., District Judge.
Pursuant to Civil L.R. 6-2, 7-12, and 16-10, Plaintiffs Circle Click Media LLC, Metro Talent, LLC, and CTNY Insurance Group LLC (collectively, "Plaintiffs") and Defendants Regus Management Group, LLC, Regus Business Centre, LLC, Regus plc, and HQ Global Workplaces LLC (collectively, "Defendants") hereby stipulate and request that the Case Management Conference, currently set for September 13, 2013, be continued to December 13, 2013, at 10:00 A.M.
Defendants requested that Plaintiffs stipulate to continue the Case Management Conference and Defendants seek relief from Civil L.R. 6-1(b) in bringing this stipulated request eight days before the September 13, 2013 Case Management Conference. ( Id. at ¶ 4).
Defendants filed their Counterclaims (Doc. 78) on May 6, 2013. Plaintiffs filed motions to dismiss (Docs. 81 and 82), which the Court granted in part and denied in part pursuant to its Order dated August 13, 2013 (Doc. 90). Defendants' First Amended Counterclaims are due on September 12, 2013. Plaintiffs' answer or other response would be due on September 26, 2013; however, the parties stipulate and request that Plaintiffs' answer or other response be due on October 3, 2013. ( See Declaration of Stephanie A. Blazewicz ¶ 3 filed concurrently herewith). Plaintiffs currently intend to file one or more Fed.R.Civ.P. 12 motions in response to some or all of the First Amended Counterclaims. ( Id. ).
The parties believe that judicial economy may be achieved by continuing the Case Management Conference currently set for September 13, 2013 to December 13, 2013, which would allow time for Plaintiffs to file and the Court to hear any motion to dismiss the Amended Counterclaims. ( See id. at ¶ 5). The parties request that they be permitted to file an updated joint Case Management Statement by December 6, 2013 (seven days prior to the requested date for the continued Case Management Conference).
Defendants' counsel has confirmed with the Court that December 13, 2013, at 10:00 A.M., is available for a Case Management Conference. ( See id. at ¶ 6).
This is the third request for a continuance of the Case Management Conference. ( Id. at ¶ 7). The parties do not believe that the requested continuance will have any effect on the overall schedule for this case. ( Id. at ¶ 8).
IT IS SO STIPULATED.
Pursuant to the Stipulation, and good cause appearing, the Court orders that the Case Management Conference currently set for September 13, 2013, is continued to December 13, 2013, at 10:00 A.M. The parties shall file an updated joint Case Management Statement no later than December 6, 2013.
The Court further orders that Plaintiffs may file an answer or other response on or ...