November 20, 2013
TASION COMMUNICATIONS INC., a Canadian corporation, dba Planet Telecom, on behalf of itself and all other similarly situated, Plaintiff,
UBIQUITI NETWORKS, INC., a Delaware corporation, Defendant.
ALAN HIMMELFARB, THE LAW OFFICES OF ALAN HIMMELFARB, Attorneys for Plaintiffs, TASION COMMUNICATIONS INC.
DAVID C. PARISI, SUZANNE HAVENS BECKMAN, PARISI & HAVENS LLP, Attorneys for Plaintiffs, TASION COMMUNICATIONS INC.
THOMAS P. HANRAHAN, SIDLEY AUSTIN LLP, Attorneys for Defendant, UBIQUITI NETWORKS, INC.
N. KATHLEEN STRICKLAND, (SBN 64816), DEVIN C. COURTEAU, (SBN 197505), JUSTIN A. ZUCKER, (SBN 284401), ROPERS, MAJESKI, KOHN & BENTLEY, Redwood City, CA, Attorneys for Defendant, UBIQUITI NETWORKS, INC.
STIPULATED REQUEST FOR ORDER CONTINUING CASE MANAGEMENT CONFERENCE AND MOTION FOR LEAVE HEARING; AND [PROPOSED] ORDER
EDWARD M. CHEN, District Judge.
Pursuant to Local Rules 6-1, 6-2, 7-12, plaintiff, Tasion Communications Inc. ("Plaintiff") and defendant, Ubiquiti Networks, Inc. ("Defendant" or "Ubiquiti") ("collectively, "Parties"), by and through their undersigned counsel, submit this Stipulated Request for Order Continuing Case Management Conference.
WHEREAS, on September 30, 2013, this Court set a Case Management Conference for December 5, 2013, at 1:30 p.m. (Dkt. No. 34);
WHEREAS, on October 28, 2013, Plaintiff filed a Motion for Leave to File First Amended Class Action Complaint (Dkt. No. 35);
WHEREAS, on November 6, 2013, this Court scheduled the hearing on Plaintiff's Motion for Leave to File First Amended Class Action Complaint ("Motion for Leave Hearing") for December 5, 2013, at 1:30 p.m. (Dkt. No. 36);
WHEREAS, on November 15, 2013, this Court, sua sponte, rescheduled the Case Management Conference and Motion for Leave Hearing from December 5, 2013, to December 10, 2013, at 1:30 p.m. (Dkt. No. 38);
WHEREAS, Defense counsel N. Kathleen Strickland is unavailable due to a long standing motion for summary adjudication hearing in Los Angeles Superior Court that day;
WHEREAS, the Parties have conferred and agreed to jointly request a continuance of the Case Management Conference and Motion for Leave Hearing from December 10, 2013, to December 11, 2013, at 10:00 a.m.;
WHEREAS, Local Rule 6-1 permits the parties to stipulate in writing to seek Court order, "for any enlargement or shortening of time that alters an event or deadline already fixed by Court order...." Local Rule 6-1(b);
WHEREAS, the requested continuance will not otherwise alter the schedule of this case; and
WHEREAS, good cause exists to grant the Parties Stipulated Request.
NOW THEREFORE, THE PARTIES JOINTLY REQUEST AN ORDER STATING:
1. The Initial Case Management Conference and Motion for Leave Hearing shall be on December 11, 2013, at 10:00 a.m., or such further date convenient for the Court.
IT IS SO STIPULATED.
ATTESTATION PURSUANT TO CIVIL LOCAL RULE 5-1(i)(3)
I, N. Kathleen Strickland, am the ECF user whose identification and password are being used to file the foregoing Stipulated Request for Order Continuing Case Management Conference and Motion for Leave Hearing; and [proposed] Order. I hereby attest that the above-referenced signatories to this Stipulated Request have concurred in this filing.
PURSUANT TO STIPULATION, IT IS SO ORDERED,