Zynga Inc. v. Playerauctions.com
Filing
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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)
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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.
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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WESTERN DIVISION
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ZYNGA GAME NETWORK INC., a
14 Delaware Corporation,
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Plaintiff,
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v.
18 PLAYER AUCTIONS, LLC, a limited
liability company,
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Defendant.
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Case No.: CV:10-2576 CBM (JCx)
JOINT STIPULATION TO
CONTINUE DISCOVERY CUT-OFF,
MOTION HEARING CUT-OFF,
PRETRIAL CONFERENCE AND
TRIAL DATES
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WHEREAS, the Court entered an order on December 16, 2010, that (1) all fact
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discovery shall be completed on or before June 30, 2011; (2) all expert discovery shall
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be completed on or before July 30, 2011; (3) settlement conference shall be held on or
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before August 30, 2011; (4) motions shall be set for oral argument on or before
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October 24, 2011 at 10:00 A.M; (5) Pre Trial Conference is set on November 14, 2011
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at 2:30 P.M.; and (6) 3-5 day Jury Trial is set on December 13, 2011 at 10:00 A.M.
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(See Dkt. No. 19);
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WHEREAS, plaintiff ZYNGA INC. (“Plaintiff”) and defendant PLAYER
AUCTIONS, LLC (“Defendant”) have agreed that the parties shall participate in a
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non-judicial dispute resolution proceeding, pursuant to Local Rule 16-15.4 Settlement
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Procedure No. 3, with The Honorable Dikran M. Tevrizian (Ret.);
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WHEREAS, Plaintiff and Defendant have scheduled a mediation with The
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Honorable Dikran M. Tevrizian (Ret.) on June 15, 2011, which the parties have been
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informed is the first available date that The Honorable Dikran M. Tevrizian (Ret.) has
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available for a mediation;
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WHEREAS, the parties have exchanged written discovery to assist with the
mediation;
WHEREAS, Plaintiff and Defendant are hopeful that this litigation can be
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resolved through mediation and wish to avoid the costs of depositions and additional
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written discovery prior to the mediation scheduled for June 15, 2011;
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WHEREAS, Plaintiff and Defendant agree that waiting to take depositions
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and/or serve additional written discovery prior to the June 15, 2011 mediation will put
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the parties too close to the currently scheduled fact discovery cut-off of June 30, 2011;
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WHEREAS, Plaintiff and Defendant hereby stipulate to enter an order
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continuing the discovery cut-off currently set for June 30, 2011 for sixty (60) days to
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enable the parties to notice and take depositions and/or serve written discovery
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following the June 15, 2011 mediation, if necessary;
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WHEREAS, Plaintiff and Defendant also hereby stipulate to enter an order
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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
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continuing the expert discovery cut-off, motion hearing cut-off, pretrial conference
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and trial dates, currently set for July 30, 2011, October 24, 2011, November 14, 2011
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and December 13, 2011, respectively, for sixty (60) days in light of the parties
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stipulation to continue the fact discovery-cut off for sixty (60) days;
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WHEREAS, this is the first stipulation for an extension of time with respect to
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the fact discovery cut-off, expert discovery cut-off, motion hearing cut-off, pretrial
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conference and trial dates as to Plaintiff and Defendant;
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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;
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NOW, THEREFORE, Plaintiff and Defendant hereby file this stipulation
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continuing the fact discovery cut-off, expert discovery cut-off, motion hearing cut-off,
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pretrial conference and trial dates for sixty (60) days, subject to the Court’s order.
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Dated: April 5, 2011
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KEATS McFARLAND & WILSON LLP
By:
/s/ David K. Caplan
David K. Caplan
Attorneys for Plaintiff
ZYNGA INC.
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Dated: April 5, 2011
DYKEMA GOSSETT
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By:
/s/ Brian H. Newman
Brian H. Newman
Attorneys for Defendant
PLAYER AUCTIONS. LLC
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SIGNATURE ATTESTATION: I hereby attest that I have authorization on file for
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any signatures indicated by a conformed signature within this e-filed document.
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/s/ David K. Caplan
David K. Caplan
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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
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