Adobe Systems Incorporated v. Rene et al
Filing
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ORDER re 27 STIPULATION WITH PROPOSED ORDER TO EXTEND ADR DEADLINE AND CONTINUE FURTHER CASE MANAGEMENT CONFERENCE filed by Adobe Systems Incorporated. Further Case Management Conference reset for 10/19/2012 08:30 AM in Courtroom 6, 17th Floor, San Francisco. Signed by Judge Charles R. Breyer on 8/1/2012. (beS, COURT STAFF) (Filed on 8/2/2012)
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Case3:11-cv-03885-CRB Document27 Filed07/31/12 Page1 of 3
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J. Andrew Coombs (SBN 123881)
andy@coombspc.com
Nicole L. Drey (SBN 250235)
nicole@coombspc.com
J. Andrew Coombs, A P. C.
517 East Wilson Avenue, Suite 202
Glendale, California 91206
Telephone:
(818) 500-3200
Facsimile:
(818) 300-3201
Attorneys for Plaintiff
Adobe Systems Incorporated
Andrew D. Winghart (SBN 225099)
drew@winghartlaw.com
Winghart Law Group
495 Seaport Court, Suite 104
Redwood City, California 94063
Telephone:
(510) 593-8546
Facsimile:
(866) 941-8593
Attorneys for Defendants Francis Pierre and
Futursoft Solutions, Inc., erroneously sued
as Francis Pierre, an individual and d/b/a
www.futursoftsolutions.com, Isaac Abady
and Computer Software Plus, Inc.,
erroneously sued as Isaac Abady a/k/a Ike
Abady a/k/a Ike Abadi a/k/a Ike Ababi, an
individual and d/b/a
www.topdealscenter.com and Top Deals
Center
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO)
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Adobe Systems Incorporated,
Plaintiff,
v.
Matthew Rene, et al.,
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Defendants.
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Adobe v. Rene, et al.: Stipulation to Extend ADR Deadline and
Continue CMC
-1-
Case No. C11-3885 CRB
STIPULATION TO EXTEND ADR
DEADLINE AND CONTINUE
FURTHER CASE MANAGEMENT
CONFERENCE AND [PROPOSED]
ORDER
Current ADR Deadline:
CMC:
Time:
Court:
July 30, 2012
August 10, 2012
8:30 a.m.
Hon. Charles R. Breyer
Case3:11-cv-03885-CRB Document27 Filed07/31/12 Page2 of 3
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PLAINTIFF Adobe Systems Incorporated (“Adobe”), by and through its counsel of record,
and Defendants Francis Pierre and Futursoft Solutions, Inc., erroneously sued as Francis Pierre, an
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individual and d/b/a www.futursoftsolutions.com, Isaac Abady and Computer Software Plus, Inc.,
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erroneously sued as Isaac Abady a/k/a Ike Abady a/k/a Ike Abadi a/k/a Ike Ababi, an individual
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and d/b/a www.topdealscenter.com and Top Deals Center (collectively “Defendants”), by and
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through their counsel of record, hereby stipulate and request as follows:
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WHEREAS a Case Management Conference was held on April 20, 2012;
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WHEREAS the Court ordered a Further Case Management Conference on June 8, 2012, to
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occur after mediation had taken place;
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WHEREAS the Parties had scheduled mediation to take place on July 17, 2012;
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WHEREAS the Further Case Management Conference was then continued until August 10,
2012, to occur after the mediation;
WHEREAS Defendants’ counsel informed Plaintiff’s counsel and the mediators on July 9,
2012, regarding a family emergency that would prevent him from attending the mediation;
WHEREAS Defendants’ counsel is a solo practitioner who did not have any associate or
co-counsel who could represent Defendants in his stead;
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WHEREAS Plaintiff and the mediators consented to the continuance of the mediation due
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to Defendants’ counsel’s extraordinary circumstances;
WHEREAS Defendants’ counsel has been out of the office for the past few weeks due to
said family emergency;
WHEREAS the Parties are now currently attempting to re-schedule the mediation for a time
in August or September;
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WHEREAS extending the ADR deadline by sixty (60) days and continuing the Case
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Management Conference until after the mediation will allow the Parties sufficient time to attempt
Adobe v. Rene, et al.: Stipulation to Extend ADR Deadline and
Continue CMC
-2-
Case3:11-cv-03885-CRB Document27 Filed07/31/12 Page3 of 3
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to resolve this matter without further intervention of the Court as well as allow sufficient time for
Defendants’ counsel to address his overdue commitments from his extended absence; and
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WHEREAS no other Court deadlines will be affected by an extension of the ADR deadline
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or continuation of the Case Management Conference.
NOW, THEREFORE, Adobe and Defendants stipulate and respectfully request the Court
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extend the ADR deadline to September 30, 2012, and continue the Joint Case Management
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Conference until October 19, 2012, or a date thereafter acceptable with the Court.
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IT IS SO STIPULATED.
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DATED: _______________
7/31/2012
J. Andrew Coombs, A Professional Corp.
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By: ________________________________________
/s/ Nicole L. Drey
J. Andrew Coombs
Nicole L. Drey
Attorneys for Plaintiff
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7/31/2012
DATED: _______________
Winghart Law Group
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/s/ Andrew D. Winghart
By: __________________________________
Andrew D. Winghart
Attorneys for Defendants
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[PROPOSED] ORDER
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PURSUANT TO REQUEST, IT IS HEREBY ORDERED that the ADR Deadline is extended to
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September 30, 2012
______________________________. It is further ordered that the Case Management Conference
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October 19, 2012 at 8:30 a.m.
shall be continued to ______________________________.
UNIT
ED
S
DATED: _______________, 2012
August 1
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D
RDERE
OO
IT IS S
RT
U
O
Hon. Charles R. Breyer
UNITED STATES DISTRICT JUDGEyer
. Bre
harles R
Judge C
ER
LI
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Adobe v. Rene, et al.: Stipulation to Extend ADR Deadline and
Continue CMC
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