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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
HANDAL & ASSOCIATES
750 B Street, Suite 2510
San Diego, California 92101
Tel: 619.544.6400 Fax: 619.696.0323
Attorneys for Plaintiff and Defendant
e.Digital Corporation
LEVI W. HEATH (SBN 220854)
levi.heath@btlaw.com
BARNES & THORNBURG LLP
2029 Century Park East, Suite 300
Los Angeles, California 90067
Telephone: (310) 284-3880
Facsimile: (310) 284-3894
CHAD S.C. STOVER, pro hac vice
chad.stover@btlaw.com
BARNES & THORNBURG LLP
1000 N. West Street, Suite 1500
Wilmington, Delaware 19801
Telephone: (302) 300-3434
Facsimile: (302) 300-3456
Attorneys for Verbatim America, LLC
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
e.Digital Corporation,
Plaintiff
,
v.
Verbatim America, LLC,
Defendant
.
Case No. 3:13-cv-02943-H-BLM
NOTICE OF SETTLEMENT
AND JOINT MOTION TO
CONTINUE ALL DEADLINES
PENDING SETTLEMENT IN
VERBATIM CASE ONLY

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
Case 3:13-cv-02943-H-BLM Document 30 Filed 11/25/14 Page 1 of 4
NOTICE OF SETTLEMENT AND CASE NO. 3:13-CV-2943-H-BLM
JOINT MOTION RE: CONTINUE ALL DEADLINES
-HANDAL & ASSOCIATES
750 B STREET
SUITE 2510
SAN DIEGO, CA 92101
TEL: 619.544.6400
FAX: 619.696.0323
e.Digital Corporation v. Verbatim America, LLC., Case Number: 3:13-cv-2943-HBLM,
has been settled
.
Plaintiff and Counter-defendant e.Digital Corporation (“Plaintiff”) and
Defendant and Counterclaimant Verbatim America, LLC (“Verbatim” or
“Defendant”)have reached an agreement in principle for the settlement of the
above-captioned matter and are in the process of finalizing their settlement
agreement
.
Plaintiff and Defendant are referred to collectively hereafter as the
“Parties.”
The Parties anticipate filing a notice of voluntary dismissal of the claims and
counterclaims in this no later than January 2, 2015.
In light of the foregoing, the Parties further make the following joint motion
seeking the following relief:
1) An order from the Court continuing all deadlines in this matter up to
and including January 2, 2015, by which date the parties expect to have executed a
settlement agreement and it is anticipated that the Parties will file a notice of
voluntary dismissal of all claims and counterclaims in the case
.
This limited continuance of deadlines is for good cause and so that justice
may be served. The Parties do not submit this request to the Court for purposes of
delay, but rather so that they 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: November 25, 2014
HANDAL & ASSOCIATES
By: /s/Pamela C. Chalk____________
Anton N. Handal
Pamela C. Chalk
Gabriel G. Hedrick
Attorneys for Plaintiff
e.Digital Corporation
Case 3:13-cv-02943-H-BLM Document 30 Filed 11/25/14 Page 2 of 4
NOTICE OF SETTLEMENT AND CASE NO. 3:13-CV-2943-H-BLM
JOINT MOTION RE: CONTINUE ALL DEADLINES
HANDAL & ASSOCIATES
750 B STREET
SUITE 2510
SAN DIEGO, CA 92101
TEL: 619.544.6400
FAX: 619.696.0323
Dated: November 25, 2014
BARNES & THORNBURG LLP
By: /s/Chad S.C. Stover ________________
Chad S.C. Stover
Attorneys for Defendant
Verbatim America, LLC
ATTESTATION OF E-FILED SIGNATURE
Pursuant to Section 2(f)(4) of the Electronic Case Filing Administrative Policies
and Procedures Manual, I, Pamela c. Chalk, attest that Chad S.C. Stover, signatory,
has read and approved the foregoing and consents to its filing in this action.
By /s/Pamela C. Chalk
Pamela C. Chalk
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