Opinion
Civil Action No.: 3:11-cv-04223-JW
10-07-2011
INNOVUS PRIME, LLC, Plaintiff, v. LG ELECTRONICS, INC., et al., Defendants.
Marc N. Bernstein (CA SBN 145837) Will B. Fitton (CA SBN 181828) THE BERNSTEIN LAW GROUP, P.C. San Francisco, California 94111 MICHAEL V. SOLOMITA (pro hac vice pending) AMSTER ROTHSTEIN & EBENSTEIN LLP New York, New York 10016 Attorneys for Defendants FUNAI CORPORATION, INC. and FUNAI ELECTRIC COMPANY, LTD
Marc N. Bernstein (CA SBN 145837)
Will B. Fitton (CA SBN 181828)
THE BERNSTEIN LAW GROUP, P.C.
San Francisco, California 94111
MICHAEL V. SOLOMITA (pro hac vice pending)
AMSTER ROTHSTEIN & EBENSTEIN LLP
New York, New York 10016
Attorneys for Defendants
FUNAI CORPORATION, INC. and
FUNAI ELECTRIC COMPANY, LTD
Judge James Ware
STIPULATION TO EXTEND TIME FOR FUNAI DEFENDANTS TO
RESPOND TO COMPLAINT PURSUANT TO CIVIL LOCAL RULE 6-1(a)
STIPULATION RE EXTENSION OF TIME TO RESPOND
Pursuant to Local Rule 6-1(a), Plaintiff Innovus Prime, LLC and Defendants Funai Electric Co., Ltd., a Japanese company, ("Funai Japan") and Funai Corporation, Inc., its United States subsidiary, ("Funai U.S."), by and through their respective counsel, hereby stipulate and agree that Funai Japan will waive service of the summons and complaint and counsel for Funai Japan will accept service on its behalf, and that the time for both Funai Japan and Funai U.S. to answer or otherwise respond to the Complaint is extended by sixty days, to and including December 12, 2011.
The sixtieth day technically falls upon Saturday, December 10, 2011. Accordingly, pursuant to Federal Rule of Civil Procedure 6, the deadline to file a response to the Complaint falls upon "the next day that is not a Saturday, Sunday, or legal holiday," which is Monday, December 12, 2011.
In accordance with N.D. Cal. General Order No. 45, Section X, the filer of this document hereby attests that the concurrence to the filing of this document has been obtained from the other signatory hereto.
Respectfully submitted,
Marc N. Bernstein
Will B. Fitton
THE BERNSTEIN LAW GROUP, P.C.
Michael V. Solomita
AMSTER, ROTHSTEIN & EBENSTEIN, LLP
By: Will B. Fitton
Attorneys for Defendants
FUNAI CORPORATION, INC. and
FUNAI ELECTRIC COMPANY, LTD
John W. Carpenter
LAW OFFICES OF JOHN W. CARPENTER LLC
By: John W. Carpenter
Attorneys for Plaintiff
INNOVUS PRIME, LLC