Free Stipulation - District Court of California - California

Case 3:08-cv-01718-VRW

Document 33

Filed 08/29/2008

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WILLIAM BLUMENTHAL General Counsel JANICE L. CHARTER Colo. Bar No. 12750 DAVID M. NEWMAN Cal. Bar No. 54218 THOMAS DAHDOUH N.Y. Bar No. 2222370 Federal Trade Commission 901 Market Street, Suite 570 San Francisco, CA 94103 Phone (415) 848-5100/ Fax (415) 848-5184 [email protected]; [email protected]; [email protected] ATTORNEYS FOR PLAINTIFF FEDERAL TRADE COMMISSION UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

FEDERAL TRADE COMMISSION, Plaintiff, Case No. C08-1718-VRW v. NEXTCLICKMEDIA, LLC, et al., Defendants. STIPULATION FOR ORDER EXTENDING DEADLINE FOR FILING RESPONSIVE PLEADINGS AND PROPOSED ORDER

WHEREAS, Defendants NextClickMedia, LLC's, Next Internet, LLC's, Kenneth Chan's and Albert Chen's (collectively, "Defendants") response to Plaintiff Federal Trade Commission's (the "FTC") Complaint is currently due on Tuesday, September 30, 2008; WHEREAS, the parties to this action have continued to exchange information with the intention of exploring the possibility of settlement of this matter; WHEREAS, the FTC is willing to extend the time for Defendants to file their responses to Plaintiff's Complaint in order to focus on settlement discussions; and WHEREAS the parties believe that additional time will increase the likelihood that they will be able to reach a settlement of this matter; Case No. C08-1718-VRW ­ Stip. Extending Deadline for Responsive Pleadings Page 1

Case 3:08-cv-01718-VRW

Document 33

Filed 08/29/2008

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NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the FTC and Defendants, through their respective counsel, that Defendants' time to move, answer or otherwise respond to the Complaint shall be and hereby is extended to and including December 1, 2008; and IT IS FURTHER STIPULATED that the Case Management Conference, currently scheduled for October 16, 2008, at 3:30 p.m., be rescheduled to January 19, 2008, at 3:30 p.m., and that the date for filing the Case Management Statement be extended to January 12, 2008.

Dated: 08/29/08

/s/_________________________________ MICHAEL C. LYNCH KELLEY DRYE & WARREN ATTORNEY FOR DEFENDANTS /s/_________________________________ JANICE L. CHARTER DAVID M. NEWMAN THOMAS N. DAHDOUH ATTORNEYS FOR PLAINTIFF

Dated: 08/29/08 12 13 14 15 16 17 18 Dated: _____________________ 19 20 21 22 23 24 25 26 27 28

ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED. ____________________________________ VAUGHN R. WALKER UNITED STATES DISTRICT COURT JUDGE

Case No. C08-1718-VRW ­ Stip. Extending Deadline for Responsive Pleadings

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