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Adobe Sys. Inc. v. Ghermazian

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO)
Nov 28, 2011
Case No. CV11-3882 JSW (N.D. Cal. Nov. 28, 2011)

Opinion

Case No. CV11-3882 JSW

11-28-2011

Adobe Systems Incorporated, Plaintiff, v. Maryam Ghermazian, et al. Defendants. ALL RELATED CLAIMS

J. Andrew Coombs, A Professional Corp. Andrew Coombs Nicole L. Drey Attorneys for Plaintiff Adobe Systems Incorporated McCurdy & Leibl, LLP John D. McCurdy Reagan E. Boyce Attorneys for Defendants Maryam Ghermazian and Technology One Online


J. Andrew Coombs (SBN 123881)

Nicole L. Drey (SBN 250235)

J. Andrew Coombs, A P. C.

Attorneys for Plaintiff

Adobe Systems Incorporated

John D. McCurdy (SBN 54091)

Reagan E. Boyce (SBN 248064)

McCurdy & Leibl, LLP

Attorneys for Defendants

Maryam Ghermazian, an individual and

d/b/a www.saveintheusa.com, and

Technology One Online d/b/a Tech 1,

Technology 1 and Technology One

Corporation

STIPULATION TO CONTINUE CASE

MANAGEMENT CONFERENCE AND

[PROPOSED] ORDER

AS MODIFIED

HEREIN

Court: Hon. Jeffrey S. White

PLAINTIFF Adobe Systems Incorporated ("Adobe"), by and through its counsel of record, and Defendants Maryam Ghermazian, an individual and d/b/a www.saveintheusa.com, and Technology One Online d/b/a Tech 1, Technology 1 and Technology One Corporation (collectively "Defendants"), by and through their counsel of record, hereby stipulate and request as follows:

WHEREAS Adobe filed its complaint on or about August 8, 2011;

WHEREAS counsel for Defendants first contacted counsel for Adobe on or about November 10, 2011, regarding her recent retention by Defendants;

WHEREAS counsel for Defendants has indicated that she will accept service for Defendants;

WHEREAS an Acknowledgment of Service is being sent to counsel for Defendants on or about November 10, 2011;

WHEREAS counsel for Defendants has not yet reviewed the Complaint and will need sufficient time to prepare a response;

WHEREAS the return of the Acknowledgment will give Defendants until January 9, 2012, to respond to the Complaint;

WHEREAS Defendant Morris Cohen a/k/a Morris Kohanian, an individual and d/b/a www.saveintheusa.com ("Cohen"), remains unserved;

WHEREAS Adobe has until December 6, 2011, to serve Defendant Cohen;

WHEREAS briefly continuing the Case Management Conference and all corresponding deadlines will provide the Parties with additional time to possibly resolve this matter informally or, alternatively, better brief the Court regarding the Parties' positions and any outstanding issues; and

WHEREAS Defendants by agreeing to a continuation of the case management conference do not intend to waive, and expressly reserve any and all rights or defenses, including those based on subject matter jurisdiction, personal jurisdiction or venue.

NOW, THEREFORE, Adobe and Defendants respectfully request the Court continue the Joint Case Management Conference for approximately ninety (90) days, or not earlier than March 2, 2012.

IT IS SO STIPULATED.

J. Andrew Coombs, A Professional Corp.

Andrew Coombs

Nicole L. Drey

Attorneys for Plaintiff Adobe Systems Incorporated

McCurdy & Leibl, LLP

John D. McCurdy

Reagan E. Boyce

Attorneys for Defendants

Maryam Ghermazian and Technology One Online

[PROPOSED] ORDER

PURSUANT TO REQUEST, IT IS HEREBY ORDERED that the Case Management Conference shall be continued to March 16, 2012 at 1:30 p.m. A joint case management statement is due on March 9, time to serve Defendant Cohen, they should file the appropriate request with the Court.

Hon. Jeffrey S. White


Summaries of

Adobe Sys. Inc. v. Ghermazian

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO)
Nov 28, 2011
Case No. CV11-3882 JSW (N.D. Cal. Nov. 28, 2011)
Case details for

Adobe Sys. Inc. v. Ghermazian

Case Details

Full title:Adobe Systems Incorporated, Plaintiff, v. Maryam Ghermazian, et al…

Court:UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO)

Date published: Nov 28, 2011

Citations

Case No. CV11-3882 JSW (N.D. Cal. Nov. 28, 2011)