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`Benjamin W. Hattenbach (SBN 186455)
`E-Mail: BHattenbach@irell.com
`Rosalyn M. Kautz (SBN 307831)
`E-Mail: RKautz@irell.com
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067
`Telephone: (310) 277-1010
`Facsimile:
`(310) 203-7199
`
`Attorneys for Defendant
`OSRAM SYLVANIA Inc.
`
`Brian Ledahl (SBN 186579)
`E-Mail: BLedahl@raklaw.com
`Neil A. Rubin (SBN 250761)
`E-Mail: NRubin@raklaw.com
`Jacob Buczko (SBN 269408)
`E-Mail: JBuczko@raklaw.com
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard 12th Floor
`Los Angeles, CA 90025
`Telephone: (310) 826-7474
`Facsimile: (310) 826-6991
`
`Attorneys for Plaintiff
`Document Security Systems, Inc.
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`SOUTHERN DIVISION
`
`
`
`Plaintiff,
`
`
`DOCUMENT SECURITY SYSTEMS,
`INC.,
`
`
`
`
`
`v.
`
`
`
`OSRAM GMBH; OSRAM OPTO
`SEMICONDUCTORS GMBH & CO.;
`and OSRAM SYLVANIA INC.,
`
`
`
`
`Defendants.
`
`
`Case No. 2:17-cv-05184-JVS-JCG
`
`
`STIPULATION TO EXTEND TIME
`FOR DEFENDANT OSRAM
`SYLVANIA INC. TO RESPOND TO
`COMPLAINT AND [PROPOSED]
`ORDER THEREON
`
`Complaint served: August 2, 2017
`Current response date: August 23, 2017
`New response date: September 22, 2017
`
`
`
`10213316
`
`
`- 1 -
`
`STIPULATION TO EXTEND TIME
`TO RESPOND TO COMPLAINT
`Case No. 2:17-cv-05184-JVS-JCG
`
`
`
`Case 2:17-cv-05184-JVS-JCG Document 28 Filed 08/18/17 Page 2 of 3 Page ID #:153
`
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`IT IS HEREBY STIPULATED by and between Plaintiff Document Security
`Systems, Inc. ("DSS") and Defendant OSRAM SYLVANIA Inc. ("OSI"), through
`their respective attorneys of record, as follows:
`WHEREAS, DSS filed its Complaint on July 13, 2017;
`WHEREAS, DSS served the Complaint on OSI on August 2, 2017;
`WHEREAS, OSI's response to the Complaint is due on August 23, 2017;
`WHEREAS, the other Defendants have not yet been served with the
`Complaint, including Defendant OSRAM GmbH and Defendant OSRAM Opto
`Semiconductor GmbH & Co., both of which are German corporations and thus are
`subject to the service procedures set forth under the Hague Convention;
`WHEREAS, on August 15, 2017, counsel for DSS and counsel for OSI met
`and conferred to engage in early settlement negotiations, and the parties plan to
`continue engaging in further settlement negotiations over the coming weeks;
`WHEREAS, good cause exists for the requested extension, as the parties are
`still meeting to continue settlement negotiations, DSS is still working on serving the
`remaining Defendants, and the extension is not being sought for purposes of delay;
`WHEREAS, the parties have made no prior request for extension of time to
`this Court;
`NOW, THEREFORE, DSS and OSI stipulate to the following extension, as
`stated in the attached [Proposed] Order, subject to the approval of the Court:
`The deadline for Defendant OSRAM SYLVANIA Inc. to answer or
`1.
`otherwise respond to the Complaint is extended to September 22, 2017.
`
`Respectfully submitted,
`By:
`/s/ Brian Ledahl
`Brian Ledahl
`RUSS AUGUST & KABAT
`
`Attorneys for Plaintiff
`Document Security Systems, Inc.
`STIPULATION TO EXTEND TIME
`TO RESPOND TO COMPLAINT
`Case No. 2:17-cv-05184-JVS-JCG
`
`DATED: August 18, 2017
`
`10213316
`
`
`- 2 -
`
`
`
`Case 2:17-cv-05184-JVS-JCG Document 28 Filed 08/18/17 Page 3 of 3 Page ID #:154
`
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`DATED: August 18, 2017
`
`By:
`
` /s/ Benjamin W. Hattenbach
`Benjamin W. Hattenbach
`IRELL & MANELLA LLP
`
`Attorneys for Defendant
`OSRAM SYLVANIA Inc.
`
`
`
`
`ATTESTATION OF AUTHORIZATION
`
`
`Pursuant to Central District of California Local Rule 5-4.3.4(a)(2)(i), 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.
`
`DATED: August 18, 2017
`
`
`
`
`
`
`By:
`
`
` /s/ Benjamin W. Hattenbach
`Benjamin W. Hattenbach
`
`
`
`
`
`10213316
`
`
`- 3 -
`
`STIPULATION TO EXTEND TIME
`TO RESPOND TO COMPLAINT
`Case No. 2:17-cv-05184-JVS-JCG
`
`
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