Free Stipulation - District Court of California - California

Case 5:07-cv-02774-JF

Document 7

Filed 07/09/2007

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David J. Miclean (CSB# 115098/[email protected]) Christina D. Jordan (CSB# 245944/[email protected]) FISH & RICHARDSON P.C. 500 Arguello St., Suite 500 Redwood City, CA 94063 Telephone: (650) 839-5070 Facsimile: (650) 839-5071 Attorneys for Defendants BANK OF AMERICA, N.A. and BANK OF AMERICA TECHNOLOGY AND OPERATIONS, INC. Robert A. Spanner, Esq. (CSB# 60308/[email protected]) TRIAL & TECHNOLOGY LAW GROUP A Professional Corporation 545 Middlefield Road, Suite 220 Menlo Park, CA 94025 Telephone: (650) 324-2223 Facsimile: (650) 324-0178 Attorneys for Plaintiff IP SOLUTIONS, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (SAN JOSE DIVISION)

IP SOLUTIONS, INC., a Delaware corporation, Plaintiff, v. BANK OF AMERICA, N.A., a National Banking Association Member; BANK OF AMERICA TECHNOLOGY AND OPERATIONS, INC., a Delaware corporation, Defendants.

Case No. 07-CV-2774 (JF) STIPULATION AND [PROPOSED] ORDER EXTENDING TIME IN WHICH DEFENDANTS MAY RESPOND TO PLAINTIFF'S COMPLAINT

TO THE COURT, TO ALL PARTIES, AND TO THE PARTIES' ATTORNEYS OF RECORD:
STIPULATION & [PROPOSED] ORDER EXTENDING TIME FOR DEFS. TO RESPOND TO PLS.' COMPLAINT Case No. 07-CV-2774 (JF)

Case 5:07-cv-02774-JF

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Filed 07/09/2007

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IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff, IP SOLUTIONS, INC. ("Plaintiff"), and Defendants, BANK OF AMERICA, N.A. and BANK OF AMERICA TECHNOLOGY AND OPERATIONS, INC. ("Defendants"), that Defendants be granted an additional fifteen (15) days in which to respond to Plaintiff's Complaint in the above-captioned matter. Based on this Stipulation and [Proposed] Order, the date by which Defendants must respond to Plaintiff's Complaint shall be extended to Friday, July 27, 2007. IT IS FURTHER HEREBY STIPULATED AND AGREED by and between Plaintiff and Defendants that the time period for noticing a motion filed in response to the Complaint for hearing pursuant to Local Rule 7-2 shall be extended to forty-two (42) days after service of the motion. This Stipulation is not entered into for purposes of delay, and will not alter the date of any event or any deadline already fixed by Court order. By entering into this stipulation, neither Plaintiffs nor Defendants waive any rights, claims or defenses they may have in this action. The Stipulation may be executed in counterparts and by facsimile signature, each of which, when executed, shall be an original and all of which together shall constitute one and the same stipulation. This Stipulation contains the entire agreement among the parties. The undersigned hereby consent to the terms set forth in the foregoing Stipulation. IT IS SO STIPULATED AND AGREED. Dated: July 9, 2007 FISH & RICHARDSON P.C.

By: /s/ David J. Miclean David J. Miclean Attorneys for Defendants BANK OF AMERICA, N.A. and BANK OF AMERICA TECHNOLOGY AND OPERATIONS, INC.

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STIPULATION & [PROPOSED] ORDER EXTENDING TIME FOR DEFS. TO RESPOND TO PLS.' COMPLAINT Case No. 07-CV-2774 (JF)

Case 5:07-cv-02774-JF

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Filed 07/09/2007

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Dated: July 9, 2007

TRIAL AND TECHNOLOGY LAW GROUP

By: /s/ Robert A. Spanner Robert A. Spanner Attorney for Plaintiff IP SOLUTIONS, INC.

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Dated: ______________,2007

_______________________________________ HONORABLE JEREMY FOGEL JUDGE OF THE UNITED STATES DISTRICT COURT

50424977.doc

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STIPULATION & [PROPOSED] ORDER EXTENDING TIME FOR DEFS. TO RESPOND TO PLS.' COMPLAINT Case No. 07-CV-2774 (JF)