`
`
`
`Ben M. Davidson (SBN 181464)
`bdavidson@davidson-lawfirm.com
`DAVIDSON LAW GROUP, ALC
`11377 West Olympic Boulevard
`Los Angeles, California 90064
`Telephone: (310) 473-2300
`Facsimile:
`(310) 473-2941
`
`Counsel for Defendant
`Everlight Americas, Inc.
`
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`DOCUMENT SECURITY
`SYSTEMS, INC.,
`
`
`Plaintiff,
`
`
`
`vs.
`
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
`
`Case No.: 2:17-cv-04273-PSG
`
`
`STIPULATION TO EXTEND TIME
`FOR DEFENDANT EVERLIGHT
`AMERICAS, INC. TO RESPOND TO
`COMPLAINT AND [PROPOSED]
`ORDER THEREON
`
`Hon. Philip S. Gutierrez
`
`
`Complaint served: June 8, 2017
` Current response date: July 11, 2017
` New response date: September 12, 2017
`
`
`
`EVERLIGHT ELECTRONICS CO.,
`LTD., AND EVERLIGHT
`AMERICAS, INC.,
`
`
`Defendants.
`
`
`
`
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`STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT
`
`
`
`Case 2:17-cv-04273-JVS-JCG Document 14 Filed 07/11/17 Page 2 of 3 Page ID #:114
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`IT IS HEREBY STIPULATED by and between the Parties, through their
`respective attorneys of record, as follows:
`WHEREAS, on June 8, 2017, Plaintiff, Document Security Systems, Inc.
`(“Plaintiff”) filed its Complaint;
`WHEREAS, on or about June 20, 2017, Plaintiff served the Complaint and
`Summons on Defendant Everlight Americas, Inc., a Delaware corporation
`(“Everlight Americas”), such that Everlight Americas’ response to the Complaint
`is due on July 11, 2017;
`WHEREAS, Defendant Everlight Electronics Co., a Taiwanese corporation
`(“Everlight Electronics”), has not yet been served in the case;
`WHEREAS, Plaintiff desires to expedite service on Everlight Electronics
`rather than use the procedures provided for service under the Hague Convention;
`WHERAS, the Parties desire to coordinate the timing of a response to the
`Complaint by both Everlight Electronics and Everlight Americas;
`WHEREAS, to promote efficiency, Everlight Electronics has agreed to
`accept service without requiring Plaintiff to comply with the provisions of service
`under the Hague Convention if the Court approves a deadline of September 12,
`2017 for both Defendants to respond to the Complaint;
`WHEREAS Everlight Americas has recently retained local counsel in this
`case in order to obtain an extension of time in which to respond to the Complaint;
`WHEREAS Plaintiff recognizes that Everlight Electronics and Everlight
`Americas will require sufficient time to prepare a response to the Complaint due
`to the need to translate documents and communicate with individuals located in
`Taiwan;
`NOW, THEREFORE, the Parties stipulate to the following extension, as
`stated in the attached [Proposed] Order, subject to the approval of the Court:
`
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`STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT
`
`
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`Case 2:17-cv-04273-JVS-JCG Document 14 Filed 07/11/17 Page 3 of 3 Page ID #:115
`
`
`
`
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`RUSS AUGUST & KABAT
`
`1.
`The deadline for Everlight Americas to answer or otherwise respond
`to the Complaint is extended to and including Tuesday, September 12, 2017.
`2.
`Upon entry of the accompanying [Proposed] Order, Everlight
`Electronics Co. Ltd. shall accept service of the Summons and Complaint, and
`Everlight Electronics Co. Ltd. shall have up to and including Tuesday, September
`12, 2017 to answer or otherwise respond to the Complaint.
`
`Dated: July 11, 2017
`
`
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`By: /s/ Brian Ledahl
`Brian Ledahl
`Attorneys for Plaintiff
`Document Security Systems, Inc.
`
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`Dated: July 11, 2017
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`DAVIDSON LAW GROUP, ALC
`
`By: /s/ Ben M. Davidson
`Ben M. Davidson
`Counsel for Defendant
`Everlight Americas, Inc.
`
`
`
`
`
`
`ATTESTATION OF AUTHORIZATION
`Pursuant to Section 2(f)(4) of the electronic case filing administrative
`policies and procedures manual, I hereby certify that the content of this document
`is acceptable to Brian Ledahl, counsel for Plaintiff, and I have obtained his
`authorization to affix his electronic signature to this document
`
`
`/s/ Ben M. Davidson
`Ben M. Davidson
`
`
`
`
`
`
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`3
`STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT
`
`
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