JOINT MOTION TO EXTEND

DEFENDANT SANDISK

CORPORATION’S TIME TO

RESPOND TO COMPLAINT

[LOCAL RULE 12.1]

(1) Judge: Hon. Cathy Ann Bencivengo

(2) Ctrm: 2 (Fourth Floor)

Pursuant to Local Civil Rule 12.1, Plaintiff e.Digital Corporation (“Plaintiff”) and

defendant SanDisk Corporation (“SanDisk”) hereby jointly present this motion for an order

extending the time for SanDisk to respond to Plaintiff’s complaint (“Complaint”).

Plaintiff filed a Complaint in this action against SanDisk alleging claims of patent

infringement on November 5, 2012. SanDisk was personally served with the Complaint on

November 14, 2012. Pursuant to Rule 12 of the Federal Rules of Civil Procedure, SanDisk’s

response to the Complaint is currently due on or before December 5, 2012.

SanDisk and/or its counsel needs more time to review this matter as well as to prepare its

Case 3:12-cv-02698-CAB-WVG Document 10 Filed 11/27/12 Page 1 of 3JOINT MOTION TO EXTEND DEFENDANT

SANDISK’S TIME TO RESPOND TO COMPLAINT 3:12-CV-2698- CAB-WVG

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HANDAL & ASSOCIATES

1200 THIRD AVE

SUITE 1321

SAN DIEGO, CA 92101

TEL: 619.544.6400

FAX: 619.696.0323

response to the Complaint. Specifically, SanDisk needs time to retain outside counsel to

represent them in this matter and/or determine whether this matter can be settled. The parties to

this Motion also wish to have an opportunity to discuss possible resolution of this matter and

need time to do so.

The parties seek an extension not for delay, but to permit the parties an opportunity to

resolve Plaintiff’s claims without the need for further litigation. Accordingly, the parties

respectfully request that SanDisk’s time to respond to the Complaint be extended to January 7,

2013.

Pursuant to Local Civil Rule 7.2, the parties hereto will separately submit a Proposed

Order granting the relief requested.

Respectfully submitted,

Dated: November 27, 2012

HANDAL & ASSOCIATES

By: /s/Pamela C. Chalk________________