COOLEY GODWARD 

KRONISH LLP 

ATTORNEYS AT LAW

SAN FRANCISCO

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1160396 v1/SF 1. 

STIPULATION AND [PROPOSED] ORDER

TO CONTINUE FURTHER CMC 

CASE NO. 3:09-CV-00879 MMC 

COOLEY GODWARD KRONISH LLP

MICHAEL G. RHODES (116127) (mrhodes@cooley.com)

BEATRIZ MEJIA (190948) (mejiab@cooley.com)

GAVIN L. CHARLSTON (253899) (gcharlston@cooley.com)

101 California Street, 5th Floor 

San Francisco, CA 94111-5800 

Telephone: (415) 693-2000 

Facsimile: (415) 693-2222 

Attorneys for Defendant 

ADZILLA, INC. 

(erroneously named herein as “ADZILLA, INC. [NEW MEDIA]”) 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SUSAN SIMON, an individual on behalf of 

herself and all other similarly situated, 

Plaintiff,

v.

ADZILLA, INC. [NEW MEDIA], a Delaware 

Corporation; CONDUCIVE 

CORPORATION, a Delaware Corporation; 

CONTINENTAL VISINET BROADBAND, 

INC., a Delaware Corporation; CORE 

COMMUNICATIONS, INC., d/b/a 

CORETEL COMMUNICATIONS, INC., a 

Delaware Corporation; and JOHN DOES 1-

50, Corporations Defendants, 

Defendant.

Case No. 3:09-CV-00879 MMC

STIPULATION AND [PROPOSED]

ORDER TO CONTINUE SECOND

CASE MANAGEMENT

CONFERENCE

Date: January 29, 2010 

Time: 10:30 a.m. 

Judge: Hon. Maxine M. Chesney 

; ORDER THEREON

Case 3:09-cv-00879-MMC Document 74 Filed 01/25/10 Page 1 of 3
COOLEY GODWARD 

KRONISH LLP 

ATTORNEYS AT LAW

SAN FRANCISCO

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1160396 v1/SF 2. 

STIPULATION AND [PROPOSED] ORDER

TO CONTINUE SECOND CMC 

CASE NO. 3:09-CV-00879 MMC 

 Pursuant to Local Rule 6-2, Plaintiff Susan Simon (“Simon”) and Defendant Adzilla, Inc. 

(“Adzilla”) hereby stipulate and agree as follows: 

 1. An initial Case Management Conference (“CMC”) was held in the abovecaptioned action on October 9, 2009. At that hearing the Court ordered a second CMC for 

January 29, 2010 at 10:30 a.m., and also ordered that the parties complete private mediation by 

January 29, 2010. 

 2. Simon and Adzilla stipulate and request that the second CMC and mediation 

deadline be continued four weeks, to February 26, 2010, for the following reasons. 

 3. The parties have been engaged in settlement discussions, but those discussions 

have slowed because one of Adzilla’s primary employees is currently undergoing treatment for a 

serious medical condition. That individual is the only available resource for analyzing Simon’s 

technical claims, and his input is necessary to prepare for mediation and determine whether 

settlement at mediation or otherwise will be feasible. 

 4. Continuation of the second CMC for an additional four week period will enable 

the parties to advance their settlement discussions and participate in mediation, if necessary. 

 5. In the event the parties are unable to resolve the case through mediation or 

otherwise within the next four weeks, they will be prepared to attend the second CMC on or after 

February 26, 2010. 

Dated: January 22, 2010 COOLEY GODWARD KRONISH LLP 

MICHAEL G. RHODES 

BEATRIZ MEJIA

GAVIN L. CHARLSTON 

/s/ Gavin L. Charlston 

Gavin L. Charlston 

Attorneys for Defendant 

ADZILLA, INC. 

Case 3:09-cv-00879-MMC Document 74 Filed 01/25/10 Page 2 of 3
COOLEY GODWARD 

KRONISH LLP 

ATTORNEYS AT LAW

SAN FRANCISCO

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1160396 v1/SF 3. 

STIPULATION AND [PROPOSED] ORDER

TO CONTINUE SECOND CMC 

CASE NO. 3:09-CV-00879 MMC 

 Dated: January 22, 2010 KAMBERLAW LLC 

SCOTT KAMBER 

DAVID A. STAMPLEY 

/s/ Scott Kamber 

Scott Kamber 

Attorneys for Plaintiff 

SUSAN SIMON 

PURSUANT TO STIPULATION, IT IS SO ORDERED: That the second Case Management 

Conference and private mediation deadline, both currently scheduled for January 29, 2010, are 

hereby continued to _____________________________________________________________. 

DATED: ______________________ ________________________________________ 

 HON. MAXINE M. CHESNEY 

 United States District Judge 

. Specifically, the deadline to complete private mediation is continued to

February 26, 2010, and the Case Management Conference is continued to March 12, 2010.

A Joint Case Management Statement shall be filed no later than March 5, 2010.

January 25, 2010

Case 3:09-cv-00879-MMC Document 74 Filed 01/25/10 Page 3 of 3