Opinion
Case No. 05 1408-BZ.
January 22, 2007
R. ALLYN TAYLOR (No. 118428), DLA PIPER US LLP, East Palo Alto, California, EUGENE M. PAK (No. 168699), DLA PIPER US LLP, San Francisco, CA, Attorneys for Plaintiff KNOWNOW, INC.
REUTERS AMERICA, INC., Carolyn H. Blankenship, Esq., Principal Legal Counsel, Intellectual Property, Reuters America LLC, New York, NY.
ADDITIONAL FURTHER STIPULATED REQUEST FOR RELIEF FROM CASE MANAGEMENT CONFERENCE SCHEDULE; [PROPOSED] ORDER
WHEREAS the parties have negotiated a settlement of this action, and exchanged a final settlement agreement for execution by the parties, and need additional time to obtain signatures of authorized individuals;
WHEREAS Defendant Reuters America, Inc. has not yet been served because of such settlement;
WHEREAS the parties wish to again extend deadlines in this action to continue to finalize such settlement;
Pursuant to Local Rule 16-2(d), the parties by their respective undersigned counsel, hereby enter into this stipulation pursuant to Local Rule 6-2, and request relief from the Order Setting Initial Case Management Conference and subsequent orders extending deadlines in this matter.
IT IS HEREBY STIPULATED by and between the parties that the case management conference and other deadlines currently set be re-scheduled as set forth below. By this stipulated request Defendant Reuters America, Inc. does not consent to jurisdiction or waive any objection to service. This Stipulation shall not be deemed an appearance by Defendant nor a waiver of any of its aforementioned rights and objections. Plaintiff KnowNow, Inc. agrees not to assert jurisdiction or waiver of service of process by virtue of Defendant entering into this stipulated request.
March 26, 2007 — Last day to meet and confer re initial disclosures, early settlement, ADR process selection, and discovery plan; last day to file Joint ADR certification with Stipulation to ADR process or Notice of Need for ADR phone conference.
March 29, 2007 — Last day to complete initial disclosures or state objection in Rule 26(f) report, file/serve Case Management Statement, and file/serve Rule 26(f) report; and
April 2, 2007 (Monday) — Case Management Conference in Courtroom G, 15th Floor, at 4:00 p.m.
IT IS SO ORDERED: