`
`Michael Bednarek (pro hac vice application pending)
`Adams and Reese LLP
`20 F Street NW, Suite 500
`Washington, District of Columbia 20001
`michael.bednarek@arlaw.com
`Telephone: (202) 478-1216
`Facsimile: (202) 478-1238
`
`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 Defendants
`Everlight Electronics Co. and
`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-JVS-JCG
`
`
`STIPULATION FOR SECOND
`EXTENSION OF TIME TO RESPOND
`TO COMPLAINT; [PROPOSED]
`ORDER THEREON
`
`Hon. James V. Selna
`
` [Proposed] Order Filed Herewith]
`
`
`
`
`EVERLIGHT ELECTRONICS CO.,
`LTD., AND EVERLIGHT
`AMERICAS, INC.,
`
`
`Defendants.
`
`
`
`
`
`
`
`1
`STIPULATION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT
`
`
`
`Case 2:17-cv-04273-JVS-JCG Document 22 Filed 09/11/17 Page 2 of 3 Page ID #:135
`
`
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`Plaintiff Document Security Systems, Inc. (“Plaintiff”) and Defendant
`Everlight Americas, Inc., a Delaware corporation (“Everlight Americas”) and
`Everlight Electronics Co., Ltd., a Taiwanese corporation (“Everlight Electronics”)
`(collectively “Defendants”) hereby stipulate pursuant to Fed. R. Civ. P. 15(a)(2)
`as follows:
`WHEREAS, in response to Plaintiffs’ Complaint, Defendants intended to
`file a motion to dismiss, including at least to dismiss certain of the claims asserted
`therein under Fed. R. Civ. P. 12(b)(6);
`
`WHEREAS, consistent with their obligations under Local Rule 7-3, counsel
`for Defendants and for Plaintiff met and conferred in good faith on September 5,
`2017;
`
`WHEREAS, after the Parties’ good faith efforts to meet and confer,
`Plaintiff confirmed on September 6, 2017, that it intended to file a First Amended
`Complaint;
`
`WHEREAS, Plaintiff offered, and the Parties have agreed that Defendants
`should have a two-week extension of the current date for Defendants’ to respond
`to the Complaint—from September 12, 2017 to September 26, 2017—because
`Plaintiff anticipates filing an amended complaint sometime during that period that
`would supersede the current Complaint and set a new deadline for a responsive
`pleading.
`
`WHEREAS, the Parties respectfully submit that good cause exists for the
`relief proposed in this Stipulation in order to foster judicial economy and judicial
`efficiency;
`
`NOW THEREFORE, the Parties herein stipulate, and request that the Court
`order, that Defendants shall have until September 26, 2017 to respond to the
`Complaint.
`IT IS SO STIPULATED.
`
`2
`STIPULATION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT
`
`
`
`Case 2:17-cv-04273-JVS-JCG Document 22 Filed 09/11/17 Page 3 of 3 Page ID #:136
`
`
`
`
`Dated: September 7, 2017
`
`
`
`
`Dated: September 7, 2017
`
`
`
`
`
`
`
`
`
`
`
`RUSS AUGUST & KABAT
`
`By: /s/ Brian Ledahl (with permission)
`Brian Ledahl
`Attorneys for Plaintiff
`Document Security Systems, Inc.
`
`
`
`DAVIDSON LAW GROUP, ALC
`
`
`
`By: /s/ Ben M. Davidson
`Ben M. Davidson
`Counsel for Defendant
`Everlight Americas, Inc.
`and Everlight Electronics Co., Ltd.
`
`
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`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
`
`
`
`
`
`
`
`
`
`
`
`3
`STIPULATION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT
`
`
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