Opinion
Rachel M. Walsh, GOODWIN PROCTER LLP, San Francisco, California, Attorney for BARE BOTTLE CORPORATION.
Jimmie L. Williams LAW OFFICES OF JIMMIE L. WILLIAMS, Alamo, California, Attorney for Plaintiff BAREBOTTLE BREWING COMPANY, INC., a California Corporation.
STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT
KANDIS A. WESTMORE, Magistrate Judge.
Pursuant to Civil Local Rules 6-2 and 7-12, Defendant Bare Bottle Corporation ("Bare Bottle") and Plaintiff Barebottle Brewing Company, Inc. ("Barebottle Brewing"), by and through their respective counsel of record, hereby stipulate as follows:
WHEREAS, Barebottle Brewing served its Complaint on June 18, 2015;
WHEREAS, BareBottle and Bare Bottle Brewing stipulated, pursuant to Local Rule 6-1, to an initial extension to respond to the Complaint of August 10, 2015;
WHEREAS, Bare Bottle has requested and Barebottle Brewing has consented to an additional 15 days for Bare Bottle's answer or response to Barebottle Brewing's complaint;
WHEREAS, an additional 15 days for Bare Bottle's answer or response to Barebottle Brewing's Complaint will alter the previous stipulated-to deadline to respond to the Complaint;
WHEREAS, the additional extension will extend the time to respond to the Complaint past the date for the parties to file their ADR Certification and meet and confer on their initial disclosures;
WHEREAS, given this extension, the parties also request an extension of the Initial Case Management Conference, which is presently set for September 8, 2015, until November 10, 2015;
WHEREAS, the parties have generally agreed on the parameters of a settlement, and, thus, there is a reasonably strong likelihood that the parties will reach a settlement over the course of the next 15 days.
NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the parties, through their respective counsel, that Bare Bottle shall answer or otherwise respond to Barebottle Brewing's Complaint by August 25, 2015.
PURSUANT TO STIPULATION, IT IS SO ORDERED.