Kos Media LLC et al v. Research 2000 et al

Filing 11

ORDER CONTINUING CMC re 10 Stipulation filed by Markos Moulitsas Zuniga, Kos Media LLC Case Management Statement due by 1/6/2011. Case Management Conference set for 1/13/2011 10:00 AM in Courtroom B, 15th Floor, San Francisco.. Signed by Judge Maria-Elena James on 11/30/2010. (mejlc1, COURT STAFF) (Filed on 11/30/2010)

Kos Media LLC et al v. Research 2000 et al Doc. 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Nathan Dooley (SBN 224331) ndooley@cozen.com Adam C. Bonin (Pro hac vice) abonin@cozen.com COZEN O'CONNOR 601 South Figueroa Street Suite 3700 Los Angeles, California 90017 Telephone: 213.892.7900 Toll Free Phone: 800.563.1027 Facsimile: 213.892.7999 Attorneys for Plaintiffs Kos Media and Markos Moulitsas Zúniga UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION KOS MEDIA, LLC and MARKOS MOULITSAS ZÚNIGA, PLAINTIFFS, VS. RESEARCH 2000 AND DELAIR D. ALI, DEFENDANTS. ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.: C10-02894 MEJ [Assigned for all purposes to Hon. Marie ­Elena James, Courtroom B, 15th Floor] JOINT STATUS REPORT, REQUEST AND STIPULATION FOR PROPOSED CONTINUANCE OF DATE for CASE MANAGEMENT CONFERENCE Current Hearing Date: Dec. 02, 2010 Requested Hearing Date: Jan. 17, 2010 TO THE COURT, ALL THE PARTIES AND THEIR ATTORNEYS OF RECORD: By and through their undersigned counsel, Plaintiffs Kos Media and Markos Moulitsas Zúniga (collectively "Plaintiffs"), and Defendants RESEARCH 2000 AND DELAIR D. ALI (collectively "Defendants") respectfully submit the following Status Report, Request and Stipulation for Continuance of the hearing date in the above captioned matter for the Case Management Conference currently set for Thursday December 02, 2010. // 1 STATUS REPORT AND REQUEST FOR CONTINUANCE Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STATUS The parties have reached an agreement as to the contours of a proper settlement but are still in the process of determining whether the execution of the proposed terms is feasible. The parties will know whether execution is feasible within one week. Accordingly, the parties hereby seek through their undersigned counsel a short continuance of the instant case management conference, currently on calendar for Thursday December 02, 2010. In view of the foregoing, IT IS HEREBY STIPULATED and agreed by and between Plaintiffs and Defendants that the instant Case Management Conference shall be continued until January 17, 2011. GOOD CAUSE Good cause exists to grant the instant Request and allow the parties additional time to execute the contemplated settlement for the following reasons: 1. The parties have negotiated a settlement in good faith and it would be a waste of judicial resources for the Court to intervene at this stage when all that needs to be seen is whether the contemplated settlement is indeed feasible. 2. The contemplated settlement would likely result in a final and complete resolution of the instant controversy. 3. If the contemplated terms are not feasible, undersigned counsel may be able to reach an alternative arrangement without burdening the Court, and in any event, the most prudent present course is to wait and see whether the contemplated settlement will result in a final and complete resolution of the instant controversy. 4. The parties request a hearing date of January 17, 2011 in view of the fact that Plaintiffs' counsel will begin a five day jury trial in Los Angeles on January 03, 2010 and in contemplation of the pending holidays in December. // // 2 STATUS REPORT AND REQUEST FOR CONTINUANCE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 IT IS SO STIPULATED DATED: November 30, 2010 HOWREY By: -/S/EMILY L. MAXWELL Attorneys for Defendants Research 2000 and Delair D. Ali DATED: November 30, 2010 COZEN O'CONNOR By: -/S/NATHAN DOOLEY ADAM C. BONIN Attorneys for Plaintiffs Kos Media and Markos Moulitsas Zuniga. PURSUANT TO STIPULATION, IT IS SO ORDERED The c.m.c. shall be on January 13, 2011 at 10:00a.m. and all dates are adjusted accordingly. DATED: November 30, 2010 By: HON. MARIE ­ ELENA JAMES Chief Magistrate Judge United States District Court Northern District of California 3 STATUS REPORT AND REQUEST FOR CONTINUANCE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 STATUS REPORT AND REQUEST FOR CONTINUANCE