Free Motion for Extension of Time to File - District Court of California - California

Case 4:07-cv-03381-SBA

Document 24

Filed 03/17/2008

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Audra M. Mori, Bar No. 162850 [email protected] Katherine M. Dugdale, Bar No. 168014 [email protected] Jennifer N. Chiarelli, Bar No. 212253 [email protected] PERKINS COIE LLP 1620 26th Street Sixth Floor, South Tower Santa Monica, CA 90404-4013 Telephone: 310.788.9900 Facsimile: 310.788.3399 Attorneys for Plaintiff MICROSOFT CORPORATION UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION MICROSOFT CORPORATION, a Washington corporation, Plaintiff, v. GENNADEY BATRAKOV, an individual, Defendant. Case No. C 07-03381 SBA MED MOTION OF EXTENSION OF TIME TO FILE STIPULATION FOR DISMISSAL Judge: Saundra B. Armstrong

Plaintiff Microsoft Corporation ("Microsoft") respectfully requests that the parties have an additional thirty days to file the Stipulation for Dismissal and Stipulated Permanent Injunction in this matter. Microsoft and Defendant Gennadey Batrakov, an individual, reached a settlement in the above matter. Counsel for Microsoft drafted settlement documents and sent the documents to defense counsel for review. Defense counsel indicated, in accordance with a Notice of Unavailability previously served in the action, he would be unavailable until March 27 to review and finalize the settlement documents.

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Case 4:07-cv-03381-SBA

Document 24

Filed 03/17/2008

Page 2 of 2

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On February 14, 2008, counsel for Microsoft filed a Notice of Settlement and indicated the parties would file with the Court a Stipulated Permanent Injunction and a Stipulation for Dismissal with Prejudice on or before March 14, 2008. However, in light of defense counsel's unavailability, the parties will need additional time to finalize and execute the settlement documents. As such, Microsoft respectfully requests that the parties have until April 14, 2008 to file the Stipulation for Dismissal and the Stipulated Permanent Injunction. DATED: March 17, 2008 PERKINS COIE LLP By /s/ Jennifer N. Chiarelli Jennifer N. Chiarelli Attorneys for Plaintiff MICROSOFT CORPORATION

41826-5197/LEGAL14078915.1

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