ANTON HANDAL (Bar No. 113812)
anh@handal-law.com
PAMELA C. CHALK (Bar No. 216411)
pchalk@handal-law.com
GABRIEL HEDRICK (Bar No. 220649)
ghedrick@handal-law.com
H
ANDAL & ASSOCIATES
1200 Third Avenue, Suite 1321
San Diego, California 92101
Tel: 619.544.6400
Fax: 619.696.0323
Attorneys for Plaintiff
e.Digital Corporation
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
e.Digital Corporation,
Plaintiff,
v.
Western Digital Corporation,
Defendant.
Case No. 3:13-cv-02910-H-BGS
PLAINTIFF E.DIGITAL
CORPORATION’S NOTICE OF
SETTLEMENT AND
UNOPPOSED
EX PARTE
MOTION TO STAY ALL
DEADLINES PENDING
SETTLEMENT
DEMAND FOR JURY TRIAL
Assigned to the Honorable
Judge Marilyn L. Huff
Courtroom 15A (Annex)
TO THE CLERK OF THE UNITED STATES DISTRICT COURT FOR
THE SOUTHERN DISTRICT OF CALIFORNIA:
NOTICE IS HEREBY GIVEN that the aforementioned matter known as
e.Digital Corporation v. Western Digital Corporation,
Case Number 3:13-cv-
02910-H-BGS, has been settled.
Plaintiff e.Digital Corporation (“Plaintiff”) and Defendant Western Digital
Corporation (“Western Digital” or “Defendant”) have reached an agreement in
principal for settlement of the above-captioned matter and are in the process of
finalizing their settlement agreement.
Plaintiff anticipates filing a notice of voluntary dismissal of this action as to
Western Digital, the only Defendant in this matter, no later than April 28, 2014.
Defendant has not appeared or otherwise responded to the Complaint in this matter
to date.
In light of the foregoing, Plaintiff further makes the following unopposed
ex
parte
motion seeking:
1) An order from the Court staying all deadlines in this matter up to and
including April 28, 2014, by which date the parties expect to have executed a
settlement agreement and it is anticipated that Plaintiff will file a notice of
voluntary dismissal of the case.
This limited stay of deadlines, which Western Digital has represented it does
not oppose, is for good cause and so that justice may be served. Plaintiff does not
submit this request to the Court for purposes of delay, but rather so that the parties
may have time to finalize a written settlement agreement and dismiss this matter
forthwith in its entirety.
Pursuant to Local Civil Rule 7.2, the parties hereto will separately submit a
Proposed Order granting the relief requested.
Dated: March 18, 2014
HANDAL & ASSOCIATES
By: /s/Pamela C. Chalk
Anton N. Handal
Pamela C. Chalk
Gabriel G. Hedrick.
Attorneys for Plaintiff
e.Digital Corporation