1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Tharan Gregory Lanier (State Bar No. 138784) 

tglanier@jonesday.com 

Gregory L. Lippetz (State Bar No. 154228) 

glippetz@jonesday.com 

Daniel H. Mao (State Bar No. 221539) 

dhmao@jonesday.com 

Joe C. Liu (State Bar No. 237356) 

jcliu@jonesday.com 

Peter D. Nestor (State Bar No. 262253) 

pnestor@jonesday.com 

JONES DAY 

1755 Embarcadero Road 

Palo Alto, CA 94303 

Telephone: 650-739-3939 

Facsimile: 650-739-3900 

Attorneys for Plaintiff/Counterdefendant 

SANDISK CORPORATION 

Bruce S. Sostek (pro hac vice) 

(bruce.sostek@tklaw.com) 

Jane Politz Brandt (pro hac vice) 

(jane.brandt@tklaw.com) 

Herbert J. Hammond (pro hac vice) 

(herbert.hammond@tklaw.com 

Max Ciccarelli (pro hac vice) 

max.ciccarelli@tklaw.com 

Richard L. Wynne, Jr. (pro hac vice) 

richard.wynne@tklaw.com 

THOMPSON & KNIGHT LLP 

1722 Routh St., Suite 1500 

Dallas, Texas 75201 

Telephone: (214) 969-1700 

Facsimile: (214) 959-1751 

Attorneys for Defendant/Counterclaimant 

LSI CORPORATION and Counterclaimant 

AGERE SYSTEMS INC. 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

SANDISK CORPORATION, 

Plaintiff, 

v. 

LSI CORPORATION, 

Defendant. 

Case No. C09-02737 WHA 

STIPULATED REQUEST FOR AN 

ORDER TO MODIFY HEARING DATE 

ON SANDISK’S MOTION FOR LEAVE 

TO FILE FIRST AMENDED 

COMPLAINT AND [PROPOSED] 

ORDER 

Date: March 18, 2010 

Time: 8:00 a.m. 

Judge: Hon. William Alsup 

Courtroom 9, 19th Floor 

LSI CORPORATION AND AGERE 

SYSTEMS INC., 

Counterclaimants, 

v. 

SANDISK CORPORATION, 

Counterdefendant. 

Case 3:09-cv-02737-WHA Document 88 Filed 02/22/10 Page 1 of 4 Case3:09-cv-02737-WHA Document87 Filed02/19/10 Page1 of 4
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Case No. C 09-02737 WHA 

- 1 -

Pursuant to Civil L.R. 6-2 and Civil L.R. 7-12, Defendant-Counterplaintiff LSI 

Corporation and Counterplaintiff Agere Systems Inc. (collectively “LSI”) and PlaintiffCounterdefendant SanDisk Corporation (“SanDisk”), through their respective counsel, hereby 

make the following Joint Stipulated Request for an Order to Modify Hearing Date on SanDisk’s 

Motion for Leave to File First Amended Complaint. 

On February 11, 2010, SanDisk filed its Notice of Motion and Motion for Leave to File 

First Amended Complaint (“Motion for Leave”) (Dkt. No. 83). Pursuant to the Notice of 

Motion, the hearing on SanDisk’s Motion for Leave is currently scheduled for March 18, 2010 at 

8:00 a.m., or as soon thereafter as the matter may be heard before the Court. 

Counsel for LSI, including lead counsel, however, have previous personal commitments 

on March 18. Spring Break for many of the schools in Dallas, Texas, where lead counsel for LSI 

is located, is being held the week of March 15-19, 2010. Lead counsel for LSI, as well as most of 

the other attorneys at Thompson & Knight LLP working on this case, made previous plans to be 

out of town on pre-paid family vacations, or are otherwise engaged with their families during this 

period of time. 

Counsel for SanDisk does not object to the rescheduling of the hearing on SanDisk’s 

Motion for Leave to File First Amended Complaint. 

Accordingly, the parties are seeking to modify the date on which the hearing on SanDisk’s 

Motion for Leave is scheduled. 

This Stipulation will not affect other dates in the case schedule. 

 

THE PARTIES HEREBY JOINTLY STIPULATE AND PROPOSE THAT: 

 The hearing on SanDisk Corporation’s Motion for Leave to File First Amended 

Complaint be rescheduled from March 18, 2010 at 8:00 a.m. to March 25, 2010 at 8:00 a.m. or as 

soon thereafter as the matter may be heard before the Court. 

Case 3:09-cv-02737-WHA Document 88 Filed 02/22/10 Page 2 of 4 Case3:09-cv-02737-WHA Document87 Filed02/19/10 Page2 of 4
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Case No. C 09-02737 WHA 

- 2 -

Dated: February 19, 2010 THOMPSON & KNIGHT LLP 

By: /s/ Jane Politz Brandt w/ permission

 Jane Politz Brandt 

Attorneys for LSI CORPORATION AND 

AGERE SYSTEMS INC. 

In accordance with General Order No. 45, Section X(B), the above signatory attests that 

concurrence in the filing of this document has been obtained from the signatory below. 

Dated: February 19, 2010 JONES DAY 

By: /s/ Joe C. Liu w/ permission 

 Joe C. Liu 

Attorneys for Plaintiff 

SANDISK CORPORATION 

Case 3:09-cv-02737-WHA Document 88 Filed 02/22/10 Page 3 of 4 Case3:09-cv-02737-WHA Document87 Filed02/19/10 Page3 of 4
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Case No. C 09-02737 WHA 

- 3 -

[PROPOSED] ORDER 

Pursuant to the Stipulation above, the Court hereby reschedules the hearing on SanDisk’s 

Motion for Leave to File First Amended Complaint from March 18, 2010 at 8:00 a.m. to March 

25, 2010 at 8:00 a.m. 

 

PURSUANT TO THE STIPULATION, IT IS SO ORDERED. 

Dated:__________________ By_________________________________ 

 THE HONORABLE WILLIAM ALSUP 

 United States District Judge 

 Northern District of California 

Case3:09-cv-02737-WHA Document87 Filed02/19/10 Page4 of 4

Please do not seek additional continuances. February 22, 2010.

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge William Alsup

Case 3:09-cv-02737-WHA Document 88 Filed 02/22/10 Page 4 of 4