Case3:13-cv-05974-RS Document30 Filed02/13/14 Page1 of 2
KRONENBERGER ROSENFELD, LLP
Karl S. Kronenberger (Bar No. 226112)
Virginia Sanderson (Bar No. 240241)
150 Post Street, Suite 520
San Francisco, CA 94108
Telephone: (415) 955-1155
Facsimile: (415) 955-1158
karl@KRInternetLaw.com
ginny@KRInternetLaw.com
Attorneys for Defendants
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
RIPPLE LABS, INC., f/k/a OpenCoin,
Inc., a California corporation,
Plaintiff,
v.
LACORE ENTERPRISES, LLC, a Texas
limited liability company; RIPPLN, INC., a
Texas corporation; and TERRY LACORE,
an individual,
Defendants.
Case No. 3:13-cv-05974-RS
JOINT NOTICE OF SETTLEMENT
AND STIPULATED REQUEST TO
CONTINUE DEADLINES;
[PROPOSED] ORDER
Plaintiff Ripple Labs, Inc., f/k/a OpenCoin, Inc. (“Plaintiff”), and Defendants Lacore
Enterprises, LLC, Rippln, Inc., and Terry LaCore (collectively, “Defendants” and together
with Plaintiff, the “Parties”) hereby state and request as follows:
WHEREAS, the Parties have reached a settlement of this case in principle;
WHEREAS, the Parties are in the process of finalizing a settlement agreement;
Case No. 3:13-cv-05974-RS
JOINT NOTICE OF SETTLEMENT
Case3:13-cv-05974-RS Document30 Filed02/13/14 Page2 of 2
WHEREAS, the Parties anticipate filing a Notice of Dismissal within thirty (30)
days of this Joint Notice;
WHEREAS, certain deadlines are currently pending in this case, such as
Defendants’ deadline to respond to the complaint and motion for preliminary injunction on
February 13, 2013, Plaintiff’s deadline to file a reply in support of its motion for
preliminary injunction on February 20, and hearing on the motion for preliminary
injunction set for March 13, 2013;
WHEREAS, the Parties believe it would be more efficient for the Parties and the
Court to stay the case, and vacate these pending deadline and hearing, while the Parties
work to finalize the settlement;
WHEREAS, the Parties hereby stipulate and request that the Court stay the case
for a period of forty-five (45) days;
WHEREAS, the Parties hereby further stipulate that Plaintiff does not and will not
waive any rights or make any concessions regarding the seriousness or immediacy of its
preliminary injunction motion and that Defendants will make no arguments to the contrary
based on Plaintiff’s stipulation to the requested stay.
IT IS SO STIPULATED.
TURNER BOYD, LLP
KRONENBERGER ROSENFELD, LLP
By: s/ Samuel A. Lewis
Samuel A. Lewis
Attorneys for Plaintiff
By: s/ Virginia Sanderson
Virginia Sanderson
Attorneys for Defendants
[PROPOSED] ORDER
PURSANT TO STIPULATION, IT IS SO ORDERED.
Date:
The Honorable Richard Seeborg
United States District Judge
Case No. 3:13-cv-05974-RS
JOINT NOTICE OF SETTLEMENT
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