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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENDE

CASE NO. C09-01483 

WDC 372,078,005v1 2-5-10 

IAN C. BALLON (SBN: 141819) 

CINDY HAMILTON (SBN: 217951) 

GREENBERG TRAURIG, LLP 

1900 University Avenue, Fifth Floor 

East Palo Alto, California 94303 

Telephone: (650) 328-8500 

Facsimile: (650) 328-8508 

Email: ballon@gtlaw.com; hamiltonc@gtlaw.com 

STEVEN M. SCHNEEBAUM (Admitted Pro Hac Vice) 

GREENBERG TRAURIG, LLP 

2101 L Street, N.W., Suite 1000 

Washington, D.C. 20037 

Telephone: 202-331-3100 

Facsimile: 202-331-3101 

Attorneys for Defendant and Counterclaimant 

Royal Canin USA Inc. 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

PET FOOD EXPRESS LTD., 

 Plaintiff, 

v. 

ROYAL CANIN USA INC., 

 Defendants. 

Case No. C09-01483 MHP 

(Related to Case No. C09-0704 MEJ) 

STIPULATION AND [PROPOSED] ORDER 

TO CONTINUE CASE MANAGEMENT 

CONFERENCE BASED ON MEDIATION 

DATE 

Courtroom: No. 15 

Judge: Hon. Marilyn H. Patel 

Location: 450 Golden Gate Ave., San Francisco 

AND RELATED COUNTERCLAIM 

Pursuant to Civil Local Rules 6-1(b) and 6-2, Plaintiff Pet Food Express Ltd. (“Pet Food 

Express”) and Defendant Royal Canin USA Inc. (“Royal Canin”) submit a Stipulation to continue the 

Case Management Conference, currently set for March 22, 2010, to June 7, 2010 or such other date 

as may be convenient for the Court. 

// 

Case 3:09-cv-01483-EMC Document 69 Filed 02/10/10 Page 1 of 3
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- 2 - 

STIPULATION TO CONTINUE CASE MANAGEMENT CONF. CASE NO. C09-01483 

WDC 372,078,005v1 2-5-10 

This request is based on the fact that the parties have agreed to further mediation before Judge 

Infante. The parties are scheduled for a mediation session with Judge Infante on May 20, 2009, 

which was the first available date when he and the parties and their attorneys were all available. 

Declaration of Steven Schneebaum ¶ 2. There have been no previous motions by either party to 

enlarge or shorten time in this case. Declaration of Steven Schneebaum ¶ 3. The time modification 

will delay the Case Management Conference for approximately ten weeks. Declaration of Steven 

Schneebaum ¶ 3. 

 The parties therefore stipulate: 

 1) To mediation before Judge Infante on or about May 20, 2010; 

 2) That the Case Management Conference currently schedule for March 22, 2010, be 

continued to June 7, 2010. 

 The parties respectfully request that this stipulation be entered as an Order of this Court. 

Dated: February 5, 2010. GREENBERG TRAURIG, LLP 

 /s/ Steven M. Schneebaum 

 Steven M. Schneebaum 

 Ian C. Ballon 

 Cindy Hamilton 

Dated: February 5, 2010. HENN, ETZEL AND MOORE INC. 

 /s/ John Douglas Moore 

 John Douglas Moore 

[PROPOSED] ORDER

IT IS SO ORDERED. 

Dated: February ___, 2010. 

 

 The Honorable Marilyn H. Patel 

9

U

NITED STATES DISTRICT COURT

NORTHERN DIS

CT OF CALIFORNIA

IT IS SO ORDERED

Judge Marilyn H. Patel

Case 3:09-cv-01483-EMC Document 69 Filed 02/10/10 Page 2 of 3
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- 3 - 

STIPULATION TO CONTINUE CASE MANAGEMENT CONF. CASE NO. C09-01483 

WDC 372,078,005v1 2-5-10 

ATTESTATION CLAUSE

I, Cindy Hamilton, am the ECF User whose ID and password are being used to file this 

STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT 

CONFERENCE BASED ON MEDIATION DATE. In compliance with General Order 45, X.B., I 

hereby attest that Steven M. Schneebaum and John Douglas Moore have concurred in this filing. 

Date: February 5, 2010. GREENBERG TRAURIG LLP 

By: /s/ Cindy Hamilton

Cindy Hamilton 

Case 3:09-cv-01483-EMC Document 69 Filed 02/10/10 Page 3 of 3