`
`
`
`Cassandra B. Roth
`ROPES & GRAY LLP
`1211 Avenue of the Americas
`New York, New York 10036-8704
`Tel: 212-596-9000
`Fax: 212-596-9090
`Cassandra.Roth@ropesgray.com
`
`Counsel for Defendant
`RAB Lighting, Inc.
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF NEW JERSEY
`
`SIPCO, LLC,
`
`Plaintiff,
`
`v.
`
`RAB LIGHTING INC.,
`
`Defendant.
`
`
`
`CIVIL ACTION FILE NUMBER:
`
`2:18-cv-08962-JLL-CLW
`
`STIPULATED APPLICATION FOR
`ORDER OF THE COURT TO
`EXTEND TIME TO ANSWER OR
`OTHERWISE REPLY, AND
`PROPOSED ORDER
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`Application pursuant to a stipulated agreement between the parties is hereby made to the
`
`United Stated District Court for the District of New Jersey by Ropes & Gray LLP, attorneys for
`
`Defendant RAB LIGHTING INC. (“RAB”), for an extension of time within which to answer or
`
`otherwise reply to Plaintiff’s Complaint for a period of thirty (30) days pursuant to Local Rule
`
`6.1, and RAB LIGHTING INC. having come before the Court solely for this extension and not
`
`having waived any defenses available to it by such appearance; and it is represented that:
`
`1.
`
`2.
`
`RAB was served with a copy of Plaintiff’s Complaint on May 14, 2018;
`
`There has been one prior request for extension of time to answer or otherwise
`
`reply, filed by Plaintiff on behalf of RAB on June 4, 2018, which is currently pending;
`
`
`
`1
`
`
`
`Case 2:18-cv-08962-JLL-CLW Document 7 Filed 06/15/18 Page 2 of 5 PageID: 645
`
`3.
`
`Provided that the prior request for extension of time is granted, RAB’s responsive
`
`pleading is due on or before June 18, 2018;
`
`With this understanding, the time to answer or otherwise reply has not expired;
`
`If RAB’s immediate request is granted, its responsive pleading would be due on
`
`4.
`
`5.
`
`July 18, 2018;
`
`6.
`
`The undersigned counsel for RAB submits that the requested extension is
`
`appropriate as RAB recently retained counsel on June 8, 2018, and the extension would allow
`
`counsel sufficient time to respond to Plaintiff’s Complaint;
`
`7.
`
`Plaintiff consents to Defendant’s proposed thirty (30) day extension requested in
`
`this motion;
`
`8.
`
`This motion has been submitted in order to comply with the requirements of
`
`Local Rule 6.1.
`
`Dated: June 15, 2018
`
`Respectfully submitted,
`
`(cid:86)(cid:18)(cid:3)(cid:38)(cid:68)(cid:86)(cid:86)(cid:68)(cid:81)(cid:71)(cid:85)(cid:68)(cid:3)(cid:37)(cid:17)(cid:3)(cid:53)(cid:82)(cid:87)(cid:75)
`___________________________________
`Cassandra B. Roth
`ROPES & GRAY LLP
`1211 Avenue of the Americas
`New York, New York 10036-8704
`Tel: 212-596-9000
`Fax: 212-596-9090
`
`Counsel for Defendant
`RAB Lighting, Inc.
`
`___s/James E. Cecchi__________
`James E. Cecchi
`Caroline F. Bartlett
`CARELLA, BYRNE, CECCHI, OLSTEIN,
`BRODY & AGNELLO, P.C.
`5 Becker Farm Road
`Roseland, NJ 07068
`Tel: 973-994-1700
`Fax: 973-994-1744
`
`Gregory J. Myers, MN #0287398
`Kristen G. Marttila, MN #0346007
`LOCKRIDGE GRINDAL NAUEN
`P.L.L.P.
`100 Washington Avenue South, Suite 2200
`Minneapolis, MN 55401
`Tel: 612-339-6900
`
`2
`
`
`
`Case 2:18-cv-08962-JLL-CLW Document 7 Filed 06/15/18 Page 3 of 5 PageID: 646
`
`Fax: 612-339-0981
`gjmyers@locklaw.com
`kgmarttila@locklaw.com
`
`Counsel for Plaintiff
`SIPCO, LLC
`
`3
`
`
`
`Case 2:18-cv-08962-JLL-CLW Document 7 Filed 06/15/18 Page 4 of 5 PageID: 647
`
`PROPOSED ORDER
`
`The above application be and hereby is GRANTED, and the time to answer or otherwise
`
`respond is extended for a period of thirty (30) days up to and including July 18, 2018, for RAB
`
`Lighting Inc. pursuant to Local Civil Rule 6.1 of the United States District Court for the District
`
`of New Jersey.
`
`By: ___________________________________
`
`4
`
`
`
`Case 2:18-cv-08962-JLL-CLW Document 7 Filed 06/15/18 Page 5 of 5 PageID: 648
`
`CERTIFICATE OF SERVICE
`
`I, the undersigned, hereby certify that a true and correct copy of the forgoing STIPULATED
`
`APPLICATION FOR ORDER OF THE COURT TO EXTEND TIME TO ANSWER OR
`
`OTHERWISE REPLY, AND PROPOSED ORDER was served on all counsel of record by filing
`
`it electronically through this Court’s ECF System.
`
`Dated June 1(cid:24), 2018
`
`(cid:86)(cid:18)(cid:3)(cid:38)(cid:68)(cid:86)(cid:86)(cid:68)(cid:81)(cid:71)(cid:85)(cid:68)(cid:3)(cid:37)(cid:17)(cid:3)(cid:53)(cid:82)(cid:87)(cid:75)
`By: ____________________________________
`Cassandra B. Roth
`
`5
`
`
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