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SEYFARTH SHAW LLP 

Selyn Hong (SBN 303398) 

E-mail: shong@seyfarth.com 

560 Mission Street, 31st Floor 

San Francisco, California 94105 

Telephone: (415) 397-2823 

Facsimile: (415) 397-8549 

SEYFARTH SHAW LLP 

Pamela Q. Devata (Admitted pro hac vice) 

E-mail: pdevata@seyfarth.com 

John W. Drury (Admitted pro hac vice) 

E-mail: jdrury@seyfarth.com 

233 S. Wacker Drive, Suite 8000 

Chicago, Illinois 60606-6448 

Telephone: (312) 460-5000 

Facsimile: (312) 460-7000 

JAMES CUNHA, an individual, on behalf of 

himself and all others similarly situated, 

Plaintiff, 

v. 

INTELLICHECK, LLC, a California Limited 

Liability Company; PROPACIFIC FRESH, INC., 

a California Corporation, and DOES 1-100, 

Defendants. 

Case No. 1:17-cv-00597-JST 

STIPULATION TO EXTEND TIME FOR 

DEFENDANT INTELLICHECK, LLC TO 

RESPOND TO THE FIRST AMENDED 

COMPLAINT 

[Filed concurrently with (1) Declaration of 

Selyn Hong; and (2) [Proposed] Order] 

Judge: Hon. Jon S. Tigar 

Complaint Filed: December 20, 2016 

First Amended Complaint Filed: March 3, 2017 

Trial Date: None Set 

Attorneys for Defendant 

INTELLICHECK, LLC 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT CALIFORNIA 

Case 3:17-cv-00597-JST Document 33 Filed 03/30/17 Page 1 of 4
Pursuant to the Civil Local Rules 6-1(b), 6-2, and 7-12, Plaintiff James Cunha and Defendant 

IntelliCheck, LLC ("IntelliCheck"), by and through their counsel, hereby stipulate as follows: 

1. The current deadline for IntelliCheck to respond to Plaintiff's First Amended Complaint 

is March 31, 2017. 

2. IntelliCheck intended to file a Rule 12(b)(6) motion to dismiss, and Plaintiff and 

IntelliCheck agree that continuing to explore the potential for early resolution would be in their 

respective best interests. Plaintiff and IntelliCheck wish to continue efforts at informal resolution and to 

avoid the time and costs associated with the filing and opposing of a motion to dismiss. 

3. Plaintiff and IntelliCheck remain actively engaged in settlement discussions and 

anticipate having a resolution in the next 14 days or, if necessary, to proceed with a motion to dismiss. 

4. To allow Plaintiff and IntelliCheck additional time to resolve the matter, Plaintiff and 

IntelliCheck further agree to extend the time for IntelliCheck to respond to Plaintiff's First Amended 

Complaint by two weeks, from March 31, 2017 to April 14, 2017. 

5. This is Plaintiff and IntelliCheck's second request for an extension of time for 

IntelliCheck to file a response to the First Amended Complaint. 

6. This stipulated request will not affect any other date or deadline in this case. 

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 

Date: March 29, 2017 KEEGAN & BAKER LLP 

/s/ Patrick N. Keegan 

Patrick N. Keegan 

James M. Treglio 

Attorney for Plaintiff 

JAMES CUNHA 

Date: March 29, 2017 SEYFARTH SHAW LLP 

/s/ Selyn Hong 

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Case 3:17-cv-00597-JST Document 33 Filed 03/30/17 Page 2 of 4
ATTESTATION PURSUANT TO LOCAL RULE 5-1(i)(3) 

I, Selyn Hong, attest that concurrence in the filing of this Stipulation has been obtained from the 

signatory, Patrick N. Keegan, counsel for Plaintiff 

Executed this 29th day of March, 2017 in San Francisco, California. 

By: /s/ Selvn Hong 

Selyn Hong 

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Case 3:17-cv-00597-JST Document 33 Filed 03/30/17 Page 3 of 4
[PROPOSED] ORDER 

PURSUANT TO STIPULATION, IT IS SO ORDERED that the deadline for Defendant 

IntelliCheck, LLC to respond to Plaintiff James Cunha's First Amended Complaint is extended from 

March 31, 2017 to April 14, 2017. 

DATED: 

Hon. Jon S. Tigar 

United States District Court Judge 

March 30, 2017

Case 3:17-cv-00597-JST Document 33 Filed 03/30/17 Page 4 of 4