Opinion
2:22-cv-00232-CDS-EJY
04-12-2023
SMART RAIN SYSTEMS, LLC, Plaintiff, v. ROHREN - UND PUMPENWERK BAUER GES M.B.H., and BAUER NORTH AMERICA, INC., Defendants.
RAY QUINNEY & NEBEKER P.C. Z. Ryan Pahnke Attorney for Plaintiff David J. Malley Designated counsel pursuant to LR IA 11-1(b) EVANS FEARS & SCHUTTERT LLP Chad R. Fears Michael S. Golenson, Esq. (pro hac vice to be filed) MASUDA, FUNAI, EIFERT & MICHELL, LTD. Attorneys for Defendants
RAY QUINNEY & NEBEKER P.C.
Z. Ryan Pahnke
Attorney for Plaintiff
David J. Malley
Designated counsel pursuant to LR IA 11-1(b)
EVANS FEARS & SCHUTTERT LLP
Chad R. Fears
Michael S. Golenson, Esq. (pro hac vice to be filed)
MASUDA, FUNAI, EIFERT & MICHELL, LTD.
Attorneys for Defendants
JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND THE DEADLINE TO RESPOND TO THE COMPLAINT
(NINTH REQUEST)
IT IS HEREBY STIPULATED AND AGREED, by Plaintiff Smart Rain Systems, LLC (“Smart Rain”), and Defendant Bauer North America, Inc. (“Bauer NA”), Defendant Rohren -und Pumpenwerk Bauer Ges.m.b.H. (“Bauer GmbH”) (collectively, “Bauer”), through their respective counsel, that the time for Bauer to respond to the Complaint be extended up to and including May 26, 2023. Bauer's current deadline to respond to the Complaint is April 14, 2023. Counsel for the parties have continued to engage in discussions and have exchanged proposed settlement terms to resolve this matter without the need for further litigation. The parties are in the process of considering and further negotiating potential settlement terms. The additional time stipulated to herein will allow the parties to continue to explore a potential early resolution of the claims in this case.
The reason for the extension is not for purposes of delay or to cause prejudice to any party, but to allow the parties to continue to engage in settlement negotiations. This is the parties' ninth stipulated request for such an extension from the Court, having had previous extensions granted on June 3, 2022 [Docket 17], August 4, 2022 [Docket 19], September 7, 2022 [Docket 21], October 5, 2022 [Docket 25], November 4, 2022 [Docket 29], December 6, 2022 [Docket 31], January 19,2023 [Docket 33] and March 2, 2023 [Docket 35]. This request complies with Local Rules IA 6-1, IA 6-2, and 7-1.
ORDER
IT IS SO ORDERED.