Opinion
Case Number CV-11-617-CW
10-25-2011
CYPRESS SEMICONDUCTOR CORPORATION, a Delaware Corporation, Plaintiff, v. DEUTSCHE BANK SECURITIES INC., a Delaware Corporation, DEUTSCHE BANK ALEX. BROWN, a Division of Deutsche Bank Securities Inc., and DEUTSCHE BANK AG, Defendants.
William J. Goines (SBN 61290) GREENBERG TRAURIG, LLP Attorneys for Defendants
William J. Goines (SBN 61290)
GREENBERG TRAURIG, LLP
Attorneys for Defendants
STIPULATION AND ORDER EXTENDING TIME FOR
DEFENDANTS TO RESPOND TO COMPLAINT
Honorable Claudia Wilken
Plaintiff and Defendants, by and through their respective undersigned counsel, stipulate and agree as follows:
WHEREAS, on June 2, 2011, the Court So Ordered the parties' initial stipulation extending the time for Defendants to respond to the Complaint in this action to July 11, 2011; and
WHEREAS, on July 8, 2011, the Court So Ordered the parties' second stipulation extending the time for Defendants to respond to the Complaint in this action through and including August 24, 2011; and
WHEREAS, on September 1, 2011, the Court So Ordered the parties' third stipulation extending the time for Defendants to respond to the Complaint in this action through and including September 23, 2011; and
WHEREAS, on September 29, 2011, the Court So Ordered the parties' fourth stipulation extending the time for Defendants to respond to the Complaint in this action through and including October 24, 2011; and
WHEREAS the parties have made substantial progress towards a final resolution of this dispute, and believe that an additional thirty (30) days would permit them to finally resolve this dispute; and
WHEREAS, accordingly, Defendants have met and conferred with Plaintiff and requested an additional 30-day extension of the time for all Defendants to move against, answer or respond to the Complaint (through and including November 23, 2011); and
WHEREAS, Plaintiff has consented to Defendants' request;
IT IS HEREBY STIPULATED, by and between Plaintiff and Defendants, through their respective counsel, and subject to Court approval, that the time for all Defendants to move against, answer or respond to the Complaint shall be extended from October 24, 2011 through and including November 23, 2011.
In accordance with General Order 45 of the United States District Court for the Northern District of California, I attest that concurrence in the filing of this document has been obtained from the undersigned counsel.
Respectfully submitted,
By Philip J. Wang (SBN 218349)
Justin S. Chang (SBN 205925)
WANG & CHANG, A PROFESSIONAL
LAW CORPORATION
One Maritime Plaza, Suite 825
San Francisco, California 94111
Telephone: (415) 599-2832
Facsimile: (415) 599-2829
phil@wangchanglaw.com
jchang@wangchanglaw.com
Attorneys for Plaintiff
By William J. Goines (SBN 61290)
GREENBERG TRAURIG, LLP
1900 University Avenue, 5th Floor
East Palo Alto, CA 94303
Telephone: (650) 328-8500
Facsimile: (650) 328-8508
goinesw@gtlaw.com
- and
Stephen L. Saxl (Pro Hac Vice Motion
To Be Filed)
Toby S. Soli (Pro Hac Vice Motion
To Be Filed)
GREENBERG TRAURIG, LLP
200 Park Avenue
New York, New York 10166
Telephone: (212) 801-9200
Facsimile: (212) 801-6400
saxls@gtlaw.com
solit@gtlaw.com
Attorneys for Defendants
ATTESTATION CLAUSE
I, William J. Goines, am the ECF User whose ID and password are being used to file this STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS TO RESPOND TO COMPLAINT. In compliance with General Order 45, X.B., I hereby attest that Philip J. Wang has concurred in this filing.
GREENBERG TRAURIG, LLP
By: William J. Goines
PURSUANT TO STIPULATION, IT IS SO ORDERED.
The Honorable Claudia Wilken
United States District Judge