Opinion
CASE NO. 3:10-cv-3517 MDL NO. 3:07-md-1827-SI
10-12-2011
Respectfully submitted, OFFICE OF THE ATTORNEY GENERAL OF THE STATE OF FLORIDA By: Nicholas J. Weilhammer R. Scott Palmer Lizabeth A. Brady Nicholas J. Weilhammer (pro hac vice) Eli Friedman Office of the Attorney General Attorneys for Plaintiff State of Florida COVINGTON & BURLING LLP By: Neil K. Roman Robert D. Wick Neil K. Roman Derek Ludwin COVINGTON & BURLING LLP Attorneys for Defendants Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Samsung Semiconductor, Inc.
Robert D. Wick
Neil K. Roman
Derek Ludwin
COVINGTON & BURLING LLP
Attorneys for Defendants Samsung Electronics Co., Ltd.,
Samsung Electronics America, Inc., and
Samsung Semiconductor, Inc.
STIPULATION AND [PROPOSED] ORDER REGARDING TIME TO
RESPOND TO AMENDED COMPLAINT
The undersigned counsel hereby respectfully request an extension of the deadline for Defendants Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Samsung Semiconductor, Inc. (collectively, the "Samsung Defendants"), to respond to the amended complaint filed by Plaintiff State of Florida on April 13, 2011, in the above-captioned litigation (the "Amended Complaint").
WHEREAS the Samsung Defendants, jointly with other Defendants in this action, filed a motion to dismiss the Amended Complaint on May 20, 2011;
WHEREAS the Court entered an order denying Defendants' joint motion to dismiss the Amended Complaint on September 15, 2011;
WHEREAS certain Defendants' deadline to answer the Amended Complaint is October 28, 2011;
WHEREAS Plaintiff State of Florida and the Samsung Defendants have agreed to a settlement in principle of the above-captioned litigation;
WHEREAS the parties would benefit from additional time to continue to negotiate the terms of that settlement;
WHEREAS extending the time for the Samsung Defendants to answer the Amended Complaint would not alter the date of any other event or deadline already fixed by the Court;
THEREFORE, Plaintiff State of Florida and the Samsung Defendants, by their respective counsel, stipulate and agree as follows:
The Samsung Defendants will have until October 28, 2011 to answer the Amended Complaint.
Respectfully submitted,
OFFICE OF THE ATTORNEY GENERAL OF
THE STATE OF FLORIDA
By: Nicholas J. Weilhammer
R. Scott Palmer
Lizabeth A. Brady
Nicholas J. Weilhammer (pro hac vice)
Eli Friedman
Office of the Attorney General
Attorneys for Plaintiff State of Florida
COVINGTON & BURLING LLP
By: Neil K. Roman
Robert D. Wick
Neil K. Roman Derek Ludwin
COVINGTON & BURLING LLP
Attorneys for Defendants Samsung Electronics Co.,
Ltd., Samsung Electronics America, Inc., and
Samsung Semiconductor, Inc.
Attestation: The filer of this document attests that the concurrence of the signatories thereto has been obtained.
[PROPOSED] ORDER
Having considered the foregoing stipulation, and for good cause appearing,
IT IS SO ORDERED.
The Honorable Susan Illston
United States District Judge