Opinion
CASE NO. 5:09-CV-03689-JF-PSG
10-06-2011
Freescale Semiconductor, Inc., a corporation, Plaintiff, v. ChipMOS Technologies, Inc., a corporation, Defendant. AND RELATED COUNTERCLAIMS.
COOLEY LLP RONALD S. LEMIEUX (120822) VIDYA R. BHAKAR (220210) SHANÉE Y.W. NELSON (221310) Attorneys for Defendant and Counterclaimant ChipMOS Technologies, Inc. GREG L. LIPPETZ (State Bar No. 154228) JACQUELINE K. S. LEE (State Bar No. 247705) JONES DAY Attorneys for Plaintiff and Counterclaim-Defendant Freescale Semiconductor, Inc.
COOLEY LLP
RONALD S. LEMIEUX (120822)
VIDYA R. BHAKAR (220210)
SHANÉE Y.W. NELSON (221310)
Attorneys for Defendant and Counterclaimant ChipMOS Technologies, Inc.
GREG L. LIPPETZ (State Bar No. 154228)
JACQUELINE K. S. LEE (State Bar No. 247705)
JONES DAY
Attorneys for Plaintiff and Counterclaim-Defendant Freescale Semiconductor, Inc.
STIPULATED REQUEST TO MODIFY BRIEFING SCHEDULE RE CHIPMOS' MOTION FOR RECONSIDERATION; DECLARATION OF SHANÉE Y. W. NELSON; [PROPOSED]-ORDER
JURY TRIAL DEMANDED
Complaint filed: July 13, 2009
Trial Date: TBD
Pursuant to Local Rule 6-2, Plaintiff and Counterclaim Defendant Freescale Semiconductor, Inc. ("Freescale") and Defendant and Counterclaimant ChipMOS Technologies, Inc. ("ChipMOS") jointly submit this Stipulated Request for an extension of time to file and serve their Opposition and Reply briefs regarding ChipMOS' Motion for Reconsideration.
The dates for filing the Response and the Reply were set by the Court's Order filed September 22, 2011 [Docket No. 156]. Under the September 22, 2011 Order, ChipMOS' opening brief is currently due on October 17, 2011, Freescale's Opposition is currently due on October 31, 2011, and ChipMOS' Reply is currently due on November 7, 2011. The parties have agreed to extend the dates for Freescale's Opposition and ChipMOS's Reply. The parties' proposed revised briefing schedule is as follows:
ChipMOS' Opening Brief: October 17, 2011
Freescale's Opposition Brief: November 7, 2011
ChipMOS's Reply Brief: November 14, 2011
This request for an extension is supported by the Declaration of Shanèe Y. W. Nelson being filed herewith.
Respectfully submitted,
COOLEY LLP
RONALD S. LEMIEUX
VID R. BHAKAR
SHANÉE Y.W. NELSON
SHANÉE Y. W. NELSON
Attorneys for Defendant and Counterclaimant ChipMOS Technologies, Inc.
In accordance with General Order No. 45, Section X(B), the above signatory attests that concurrence in the filing of this document has been obtained from the signatory below.
JONES DAY
GREG L. LIPPETZ
JACQUELINE K. S. LEE
JACQUELINE K. S. LEE
Attorneys for Plaintiff and Counterclaim-Defendant Freescale Semiconductor, Inc.
DECLARATION OF SHAN ÉE Y. W. NELSON
I, Shanèe Y. W. Nelson, declare
1. I am an attorney at the law firm of Cooley LLP, counsel in this action for Defendant and Counterclaimant ChipMOS Technologies, Inc. ("ChipMOS"). I have personal knowledge of the facts contained within this declaration, and if called as a witness, could testify competently to the matters contained herein.
2. On Friday, September 23, 2011 I contacted Jacqueline Lee, counsel for Freescale, requesting Freescale's agreement to modify the briefing schedule set by the Court's September 22, 2011 Order to accommodate the international travel schedule of Ron Lemieux, counsel for ChipMOS. Mr. Lemieux's travel plans were booked several weeks prior to the Court's Order.
3. The parties have conferred and agreed to an extension of time to file the Opposition and Reply briefs regarding ChipMOS' Motion for Reconsideration pursuant to the schedule requested in the Stipulated Request.
4. There have been no previous modifications to the briefing schedule set in the Court's September 22, 2011 Order.
5. The requested time modification will have no effect on any other deadlines set by the Court or on the schedule for this case.
I declare under penalty of perjury that to the best of my knowledge the foregoing is true and correct. Executed on September 27, 2011 in Palo Alto, California.
Shanèe Y. W. Nelson
ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
Jeremy Fogel
United States District Judge