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 ...