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`Gregory Dovel (SBN 135387)
`Email: greg@dovel.com
`Richard Lyon (SBN 229288)
`Email: rick@dovel.com
`DOVEL & LUNER, LLP
`201 Santa Monica Blvd., Suite 600
`Santa Monica, CA 90401
`Telephone: 1.310.656.7066
`Attorneys for Plaintiff
`NETWORK-1 TECHNOLOGIES, INC.
`
`Alexis Adian Smith (SBN 274429)
`asmith@jonesday.com
`JONES DAY
`555 South Flower Street
`Fiftieth Floor
`Los Angeles, CA 90071
`Telephone: +1.213.489.3939
`Facsimile: +1.213.243.2539
`Attorneys for Defendant
`HIKVISION USA, INC.
`
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`
`NETWORK-1 TECHNOLOGIES,
`INC.,
`
`Plaintiff,
`
`v.
`HIKVISION USA, INC.,
`Defendant.
`
`Case No. 2:22-CV-08050 CJC(JDEx)
`JOINT AND UNOPPOSED
`MOTION TO CONTINUE THE
`HEARING ON DEFENDANT’S
`PARTIAL MOTION TO DISMISS
`AND CORRESPONDING REPLY
`BRIEF, AND THE DATE TO ISSUE
`A SCHEDULING ORDER
`Judge: Hon. Cormac J. Carney
`
`
`
`
`
`
`
`Motion to Continue
`-1-
`2:22-CV-08050 CJC (JDEx)
`
`
`
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`
`
`Case 2:22-cv-08050-CJC-JDE Document 34 Filed 06/08/23 Page 2 of 3 Page ID #:403
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`The parties to this action hereby request that the Court continue for three
`weeks (a) the hearing for Defendant’s Partial Motion to Dismiss and the date for
`Defendant to file its corresponding Reply Brief, and (b) the date to issue a
`Scheduling Order and the corresponding dates for an early meeting of counsel and
`filing a report.
`
`Defendant Hikvision filed a Notice of Motion and Partial Motion to Dismiss
`Under Federal Rule of Civil Procedure 12(b)(6). Dkt. 27. Pursuant to the Court’s
`Order (Dkt. 33), the hearing on Defendant’s Motion was continued and is currently
`scheduled for June 26, 2023. Defendant’s Reply brief is currently due June 12,
`2023. The parties request that the hearing be continued to July 17, 2023, and that
`the deadline for Defendant to submit its Reply brief be continued to July 3, 2023.
`
`The Court provided notice that it intends to issue a Scheduling Order on July
`6, 2023, and that the parties hold an early meeting of counsel not later than 21 days
`in advance of that date and to file a report of such meeting not later than 14 days
`thereafter. Dkt. 28. The parties request that the date to issue a Scheduling Order be
`continued to July 27, 2023, with the corresponding deadlines for the early meeting
`of counsel and a report to be adjusted accordingly.
`
`The parties reached a settlement and are in the process of documenting the
`settlement. The parties request a three-week continuance for each of these dates to
`finalize documenting the terms of the settlement. Good cause exists for this
`extension. Granting this extension will conserve party and Court resources. See
`Declaration of Richard Lyon.
`
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`
`
`
`- 2 -
`
`Motion to Continue
` 2:22-CV-08050 CJC (JDEx)
`
`
`
`Case 2:22-cv-08050-CJC-JDE Document 34 Filed 06/08/23 Page 3 of 3 Page ID #:404
`
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`Dated:
`
`
`June 8, 2023
`
`Respectfully submitted,
`DOVEL & LUNER, LLP
`
`Dated:
`
`
`June 8, 2023
`
`By: /s/ Richard Lyon
`Richard Lyon
`Attorney for Plaintiff
`NETWORK-1 TECHNOLOGIES, INC.
`
`Respectfully submitted,
`JONES DAY
`
`
`
`By: /s/ Alexis Adian Smith
`Alexis Adian Smith
`Attorney for Defendant
`HIKVISION USA, INC.
`
`ATTESTATION
`In accordance with Local Rule 5-4.3.4(a)(2), I attest that concurrence in the
`filing of this document has been obtained from all other signatories listed and on
`whose behalf this filing is submitted.
`
`
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`/s/ Richard Lyon
`Richard Lyon
`
`
`- 3 -
`
`Motion to Continue
` 2:22-CV-08050 CJC (JDEx)
`
`
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