Opinion
Case No. CV11-3885 CRB
11-04-2011
Adobe Systems Incorporated, Plaintiff, v. Matthew Rene; Francis Pierre, an individual and d/b/a www.futursoftsolutions.com; Isaac Abady a/k/a Ike Abady a/k/a Ike Ababi, an individual and d/b/a www.topdealscenter.com and Top Deals Center; Computer Software Plus, Inc.; Nati Aviv; Shahar Ben-Yehuda; and Does 1-10, inclusive, Defendants.
J. Andrew Coombs (SBN 123881) Annie S. Wang (SBN 243027) Nicole L. Drey (SBN 250235) J. Andrew Coombs, A Prof. Corp. Attorneys for Plaintiff Adobe Systems Incorporated
J. Andrew Coombs (SBN 123881)
Annie S. Wang (SBN 243027)
Nicole L. Drey (SBN 250235)
J. Andrew Coombs, A Prof. Corp.
Attorneys for Plaintiff
Adobe Systems Incorporated
STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE AND
[PROPOSED] ORDER
Date: November 18, 2011
Time: 8:30 a.m.
Court: Hon. Charles R. Breyer
PLAINTIFF Adobe Systems Incorporated ("Plaintiff") and Defendants Francis Pierre and Futursoft Solutions, Inc., erroneously sued as Francis Pierre, an individual and d/b/a www.futursoftsolutions.com, Isaac Abady and Computer Software Plus, Inc., erroneously sued as Isaac Abady a/k/a Ike Abady a/k/a Ike Abadi a/k/a Ike Ababi, an individual and d/b/a www.topdealscenter.com and Top Deals Center (collectively "Defendants"), by and through their respective counsel of record, hereby stipulate and request as follows:
WHEREAS Plaintiff filed its Complaint on or about August 8, 2011;
WHEREAS Plaintiff Defendants Pierre and Futursoft Solutions, Inc. were personally served on or about August 26, 2011;
WHEREAS the original deadline to respond to the Complaint for Defendants Pierre and Futursoft Solutions, Inc. was September 15, 2011;
WHEREAS Plaintiff sub-served Defendants Abady and Computer Software Plus, Inc. on or about August 29, 2011;
WHEREAS the original deadline to respond to the Complaint for Defendants Abady and Computer Software Plus, Inc., was September 28, 2011;
WHEREAS Defendants recently retained the same counsel for joint representation in this action;
WHEREAS the Parties are currently discussing resolution of Plaintiff's claims without further intervention of the Court;
WHEREAS the Parties are concurrently filing a Stipulation to Extend Time to Respond and [Proposed] Order seeking an extension of time for Defendants to respond to the Complaint to November 18, 2011;
WHEREAS Plaintiff continues attempts to serve the remaining defendants Nati Aviv and Shahar Ben-Yehuda and have until December 6, 2011, to effect service pursuant to Fed. R. Civ. P. 4(m);
WHEREAS continuing the Case Management Conference until a date after all Defendants have been served, answered, and can participate in the preparation of the Joint Case Management Statement would be the most efficient use of the Court's time and resources; and
NOW, THEREFORE, the Parties respectfully request the Court continue the Case Management Conference for approximately sixty (60) days, or not earlier than January 20, 2012.
J. Andrew Coombs, A Professional Corp.
By: J. Andrew Coombs
Annie S. Wang
Nicole L. Drey
Attorneys for Plaintiff Adobe Systems Incorporated
Winghart Law Group
By: Andrew D. Winghart
Attorney for Defendants Francis Pierre and Futursoft
Solutions, Inc., erroneously sued as Francis Pierre, an
individual and d/b/a www.futursoftsolutions.com,
Isaac Abady and Computer Software Plus, Inc.,
erroneously sued as Isaac Abady a/k/a Ike Abady
a/k/a Ike Abadi a/k/a Ike Ababi, an individual and
d/b/a www.topdealscenter.com and Top Deals Center
[PROPOSED] ORDER
PURSUANT TO REQUEST, IT IS HEREBY ORDERED that the Case Management Conference shall be continued until Friday, January 20, 2012 at 8:30 a.m.
Charles R. Breyer
UNITED STATED DISTRICT COURT