Zynga Inc. v. Playerauctions.com

Filing 22

Joint Stipulation to Continue Discovery Cut-Off, Motion Hearing Cut-Off, Pretrial Conference and Trial Dates re: Minutes of In Chambers Order/Directive - no proceeding held, Set/Reset Deadlines/Hearings,,,, 19 (Attachments: # 1 Proposed Order)(Caplan, David)

Download PDF
1 2 3 4 5 6 7 8 Dennis L. Wilson (Bar No. 155407) dwilson@kmwlaw.com David K. Caplan (Bar No. 181174) dcaplan@kmwlaw.com Tara D. Rose (Bar No. 256079) trose@kmwlaw.com KEATS McFARLAND & WILSON LLP 9720 Wilshire Boulevard Penthouse Suite Beverly Hills, California 90212 Telephone: (310) 248-3830 Facsimile: (310) 860-0363 Attorneys for Plaintiff ZYNGA INC. 9 10 UNITED STATES DISTRICT COURT 11 CENTRAL DISTRICT OF CALIFORNIA 12 WESTERN DIVISION 13 ZYNGA GAME NETWORK INC., a 14 Delaware Corporation, 15 Plaintiff, 16 17 v. 18 PLAYER AUCTIONS, LLC, a limited liability company, 19 Defendant. 20 21 22 23 24 25 26 27 28 Case No.: CV:10-2576 CBM (JCx) JOINT STIPULATION TO CONTINUE DISCOVERY CUT-OFF, MOTION HEARING CUT-OFF, PRETRIAL CONFERENCE AND TRIAL DATES 1 WHEREAS, the Court entered an order on December 16, 2010, that (1) all fact 2 discovery shall be completed on or before June 30, 2011; (2) all expert discovery shall 3 be completed on or before July 30, 2011; (3) settlement conference shall be held on or 4 before August 30, 2011; (4) motions shall be set for oral argument on or before 5 October 24, 2011 at 10:00 A.M; (5) Pre Trial Conference is set on November 14, 2011 6 at 2:30 P.M.; and (6) 3-5 day Jury Trial is set on December 13, 2011 at 10:00 A.M. 7 (See Dkt. No. 19); 8 9 WHEREAS, plaintiff ZYNGA INC. (“Plaintiff”) and defendant PLAYER AUCTIONS, LLC (“Defendant”) have agreed that the parties shall participate in a 10 non-judicial dispute resolution proceeding, pursuant to Local Rule 16-15.4 Settlement 11 Procedure No. 3, with The Honorable Dikran M. Tevrizian (Ret.); 12 WHEREAS, Plaintiff and Defendant have scheduled a mediation with The 13 Honorable Dikran M. Tevrizian (Ret.) on June 15, 2011, which the parties have been 14 informed is the first available date that The Honorable Dikran M. Tevrizian (Ret.) has 15 available for a mediation; 16 17 18 WHEREAS, the parties have exchanged written discovery to assist with the mediation; WHEREAS, Plaintiff and Defendant are hopeful that this litigation can be 19 resolved through mediation and wish to avoid the costs of depositions and additional 20 written discovery prior to the mediation scheduled for June 15, 2011; 21 WHEREAS, Plaintiff and Defendant agree that waiting to take depositions 22 and/or serve additional written discovery prior to the June 15, 2011 mediation will put 23 the parties too close to the currently scheduled fact discovery cut-off of June 30, 2011; 24 WHEREAS, Plaintiff and Defendant hereby stipulate to enter an order 25 continuing the discovery cut-off currently set for June 30, 2011 for sixty (60) days to 26 enable the parties to notice and take depositions and/or serve written discovery 27 following the June 15, 2011 mediation, if necessary; 28 WHEREAS, Plaintiff and Defendant also hereby stipulate to enter an order -1- CASE NO. CV:10-2576 CBM (JCx) JOINT STIP. TO CONT. FACT DISCOVERY CUT-OFF, EXPERT DISCOVERY CUT-OFF, PRE TRIAL CONF. AND TRIAL DATES 1 continuing the expert discovery cut-off, motion hearing cut-off, pretrial conference 2 and trial dates, currently set for July 30, 2011, October 24, 2011, November 14, 2011 3 and December 13, 2011, respectively, for sixty (60) days in light of the parties 4 stipulation to continue the fact discovery-cut off for sixty (60) days; 5 WHEREAS, this is the first stipulation for an extension of time with respect to 6 the fact discovery cut-off, expert discovery cut-off, motion hearing cut-off, pretrial 7 conference and trial dates as to Plaintiff and Defendant; 8 9 10 WHEREAS, this stipulation is entered into so that the parties may effectively engage in the mediation and discovery process, is not for the purpose of delay, and is without prejudice to any of the parties hereto; 11 NOW, THEREFORE, Plaintiff and Defendant hereby file this stipulation 12 continuing the fact discovery cut-off, expert discovery cut-off, motion hearing cut-off, 13 pretrial conference and trial dates for sixty (60) days, subject to the Court’s order. 14 15 Dated: April 5, 2011 16 KEATS McFARLAND & WILSON LLP By: /s/ David K. Caplan David K. Caplan Attorneys for Plaintiff ZYNGA INC. 17 18 19 20 Dated: April 5, 2011 DYKEMA GOSSETT 21 22 23 By: /s/ Brian H. Newman Brian H. Newman Attorneys for Defendant PLAYER AUCTIONS. LLC 24 25 SIGNATURE ATTESTATION: I hereby attest that I have authorization on file for 26 any signatures indicated by a conformed signature within this e-filed document. 27 /s/ David K. Caplan David K. Caplan 28 -2- CASE NO. CV:10-2576 CBM (JCx) JOINT STIP. TO CONT. FACT DISCOVERY CUT-OFF, EXPERT DISCOVERY CUT-OFF, PRE TRIAL CONF. AND TRIAL DATES

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?