ELECTRONIC FRONTIER FOUNDATION
                           
                                                         
                                                        

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION




FORD MOTOR COMPANY, et al.,


Plaintiffs,

v. Case No. 00-CV-71544-DT

Hon. Robert H. Cleland

GREAT DOMAINS.COM, INC., et al.,


Defendants.

____________________________________/



STIPULATED ORDER FOR EXTENSION OF TIME



In accordance with Local Rule 7(a)(1), the Plaintiffs, Ford Motor Company, Jaguar Cars, Ltd., Aston Martin Lagonda, Ltd., Volvo Trademark Holding, AB (collectively “Plaintiffs”), and any Defendants represented by the Electronic Frontier Foundation (the “EFF Defendants”), including the following Defendants:

Defendant Domain Name(s)

  • Tom Cooper vintagevolvos.com,

  • Bob Emmert volvoguy.com,

  • Alfonso Fiero lincolntrucks.com,

  • Paul Brown jaguarenthusiastsclub.com

  • John Hall and jaguarcenter.com

Gapmount, Ltd.


  • Wallace Rawson 4fordparts.com

and RAD*TECH. 4fordtrucks.com,


individually and collectively, have consulted and concurred upon the extensions of time set forth in this Stipulated Order:

1. The EFF Defendants shall have an extension of time, through and including January 12, 2001, to file their Reply to the Plaintiffs’ Opposition to the EFF Defendants’ Rule 12(b)(1) Motion to Dismiss the Plaintiffs’ In Rem Claims for lack of Subject-Matter Jurisdiction (and other Motions specified in the Plaintiffs’ Opposition).

2. EFF Defendants shall have the obligation to serve this Extension Order, once signed by the Court, upon all Parties and/or Attorneys of Record, but shall be permitted to serve the signed Extension Order along with the EFF Defendants Reply on January 12, 2001.

WHEREFORE, the Plaintiffs and the above-listed Defendants respectfully submit this Stipulated Order for an extension of time, to and including January 12, 2001, to file and serve the papers set forth above.

Dated: December 29, 2000. Respectfully submitted,

FOR THE EFF DEFENDANTS,


_____________________

Eric C. Grimm (MI Bar No. P58990)

CyberBrief, PLC

320 South Main Street

Ann Arbor, Michigan 48107-7341

734.332.4900

Fax 734.332.4901


David Lowenschuss

David H. Lowenschuss, PLC

2020 Shadford Road

Ann Arbor, MI 48104


Cindy Cohn

Legal Director

Electronic Frontier Foundation

1550 Bryant Street, Suite 725

San Francisco, CA 94103

415.436.9333


I hereby certify, under 28 U.S.C. § 1746, that, on December 29, 2000, at approximately 3:00 in the afternoon, Jodi Munn Schebel of the Dickinson, Wright Law firm, on behalf of the Plaintiffs, confirmed by telephone that Plaintiffs agree to an extension of time for the EFF Defendants’ Reply, to and including January 12, 2001. Ms. Schebel had to leave the office shortly thereafter and Kathleen Land was not in the office on December 29, 2000. Because I am leaving on vacation on December 30, 2000, I have filed these extension papers with Ms. Schebel’s (and Plaintiffs’) authorization and consent, although it was impracticable under the circumstances to secure a signature of a representative of the Plaintiff prior to the time of filing. The extension of time is unopposed.


A file-stamped copy of this Agreed Order will be transmitted to Ms. Schebel by facsimile on December 29, 2000.


I certify under penalty of perjury that the foregoing is true and correct.


Executed on December 29, 2000.


_________________________

Eric C. Grimm


It is so ORDERED.


DATED this ___ day of ______________, 2000.



________________________

Hon. Robert H. Cleland

United States District Judge



4





 

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