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`BLANEY HARPER (pro hac vice
`admission pending)
`bharper@jonesday.com
`JONES DAY
`51 Louisiana Avenue, N.W.
`Washington, D.C. 20001
`Telephone: +1.202.879.3939
`Facsimile: +1.202.626.1700
`
`JACQUELINE K. S. LEE (SBN 247705)
`jkslee@jonesday,com
`JONES DAY
`1755 Embarcadero Road
`Palo Alto, CA 94303
`Telephone: +1.650.739.3939
`Facsimile: +1.650.739.3900
`
`Attorneys for Defendant
`CREE, INC.
`.
`
`BRIAN LEDAHL (SBN 186579)
`bledahl@raklaw.com
`NEIL A. RUBIN (SBN 250761)
`nrubin@raklaw.com
`JACOB BUCZKO (SBN 269408)
`jbuczko@raklaw.com
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard 12th Floor
`Los Angeles, California 90025
`Telephone: +1.310.826.7474
`Facsimile: +1.310.826.6991
`Attorneys for Plaintiff
`DOCUMENT SECURITY
`SYSTEMS, INC.
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`SOUTHERN DIVISION
`
`DOCUMENT SECURITY SYSTEMS,
`INC.,
`
`v.
`CREE, INC.,
`
`Plaintiff,
`
`Defendant.
`
`Case No. 2:17-cv-04263-JVS-JCG
`STIPULATED REQUEST AND
`[PROPOSED] ORDER TO
`EXTEND TIME TO RESPOND
`TO AMENDED COMPLAINT
`
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`
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`
`Stipulated Request and [Proposed] Order to Extend
`Time to Respond to Amended Complaint
`CASE No. 2:17-cv-04263-JVS-JCG
`
`
`
`
`
`Case 2:17-cv-04263-JVS-JCG Document 19 Filed 07/28/17 Page 2 of 3 Page ID #:245
`
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`Defendant Cree, Inc. (“Cree”) and Plaintiff Document Security Systems, Inc.
`(“DSS”) hereby make the following stipulated request through their respective
`counsel of record:
`WHEREAS, Plaintiff DSS filed the Complaint on June 8, 2017;
`WHEREAS, Plaintiff DSS served the Complaint on Cree on June 9, 2017;
`WHEREAS, Plaintiff DSS filed and served its First Amended Complaint For
`Patent Infringement July 14, 2017;
`WHEREAS Cree’s response to Plaintiff’s amended complaint is currently
`due on July 28, 2017;
`WHEREAS, the parties have met and conferred and agreed that Cree shall
`have a 14-day extension of time in which to answer or otherwise respond to the
`Amended Complaint, such that Cree’s extended responsive pleading due date will
`be August 11, 2017;
`WHEREAS, good cause exists for the extension, as the parties are still
`meeting to continue settlement negotiations and this extension is not being sought
`for purposes of delay;
`WHEREAS, this extension of time does not alter the date of any event or any
`deadline already fixed by the Court;
`NOW, THEREFORE, IT IS HEREBY REQUESTED AND STIPULATED
`by and among counsel for Plaintiff and Defendant that Cree’s deadline to answer or
`otherwise respond to the Amended Complaint is extended to August 11, 2017.
`IT IS SO STIPULATED.
`
`
`
`
`
`
`
`
`
`-1-
`
`Stipulated Request and [Proposed] Order to Extend
`Time to Respond to Amended Complaint
`CASE No. 2:17-cv-04263-JVS-JCG
`
`
`
`Case 2:17-cv-04263-JVS-JCG Document 19 Filed 07/28/17 Page 3 of 3 Page ID #:246
`
`
`
`Dated:
`
`
`July 28, 2017
`
`JONES DAY
`
`
`
`By:
`
`/s/ Jacqueline K. S. Lee
`Jacqueline K. S. Lee
`Attorneys for Defendant
`CREE, INC.
`
`
`
`
`
`In accordance with Local Rule 5-4.3.4(a)(2)(i), the above signatory attests
`that concurrence in the filing of this document has been obtained from the signatory
`below.
`
`
`Dated: July 28, 2017
`
`
`RUSS AUGUST & KABAT
`
`By: /s/ Brian Ledahl
` Brian Ledahl
`Attorneys for Plaintiff
`DOCUMENT SECURITY SYSTEMS,
`INC.
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`PURSUANT TO STIPULATION, IT IS SO ORDERED
`
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`Dated:__________________________
`
`
`By:
`The Hon. James V. Selna
`United States District Judge
`
`-2-
`
`Stipulated Request and [Proposed] Order to Extend
`Time to Respond to Amended Complaint
`CASE No. 2:17-cv-04263-JVS-JCG
`
`
`
`
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`NAI-1502891997v1
`
`
`
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`
`
`
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