California Consortium for Agricultural Export, LLC v. Zhonglin Co., LLC

Filing 23

STIPULATION and ORDER TO PERMIT FILING OF AMENDED COUNTERCLAIM AND TO EXTEND DEADLINES AND DATES: Pretrial Conference set for October 21, 2014 at 08:30 AM in Courtroom 4 (LJO) before District Judge Lawrence J. O'Neill., Jury Trial set for December 9,2014 at 08:30 AM in Courtroom 4 (LJO) before District Judge Lawrence J. O'Neill., signed by Magistrate Judge Michael J. Seng on 04/22/2014. (Yu, L)

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Thomas P. Hanrahan, (SBN 110609)
[e-mail]
Michelle B. Goodman (SBN 218607)
[e-mail]
SIDLEY AUSTIN LLP
555 West Fifth Street, Suite 4000
Los Angeles, California 90013
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Zhonglin Co., LLC

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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CALIFORNIA CONSORTIUM FOR
AGRICULTURAL EXPORT, LLC, a
California Limited Liability Company,

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Plaintiff,

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vs.

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ZHONGLIN CO., LLC a California Limited
Liability Company; and DOES 1 through 20,
inclusive,

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Defendants.

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Case No. 1:13−CV−00441−LJO−MJS
Assigned to: Hon. Lawrence J. O’Neill
STIPULATION AND ORDER TO PERMIT
FILING OF AMENDED
COUNTERCLAIM AND TO EXTEND
DEADLINES AND DATES

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IT IS HEREBY STIPULATED between the parties that Defendant-Counterclaimant

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may file its First Amended Answer and Counterclaims on or before March 31, 2014.
IT IS FURTHER STIPULATED between the parties that the following deadlines

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extended sixty (60) days:

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1. non-expert discovery deadline:

from March 14, 2014, to May 30, 2014,

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2. expert disclosure deadline:

from March 27, 2014, to May 26, 2014,

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3. rebuttal expert disclosure deadline:

from April 10, 2014, to June 9, 2014,

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4. expert discovery deadline:

from April 25, 2014, to June 24, 2014,

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5. non-dispositive motion deadline:

from April 3, 2014, to June 2, 2014,

ACTIVE 200702368v.3
STIPULATION AND ORDER TO EXTEND DEADLINES AND PRETRIAL CONFERENCE

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6. dispositive motion deadline:

from April 3, 2014, to June 30, 2014,

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IT IS FURTHER STIPULATED between the parties that the following dates be extended:
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1. dispositive motion hearing:

from May 13, 2014, at 8:30 a.m., to August 15,
2014, at 8:30 a.m., Courtroom 4,

2. pretrial conference:

from June 26, 2014, at 8:30 a.m., to October
21, 2014, at 8:30 a.m., Courtroom 4, and

3. jury trial:

from September 9, 2014, at 8:30 a.m., to
December 9, 2014, at 8:30 a.m., Courtroom
4.

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Dated: April 22, 2014

SIDLEY AUSTIN LLP

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By:
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/s/ Thomas P. Hanrahan
Thomas P. Hanrahan
Attorneys for Defendant
Zhonglin Co., LLC

MOTSCHIEDLER, MICHAELIDES,
WISHON, BREWER & RYAN, LLP

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By:

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/s/ Russell K. Ryan
Russell K. Ryan,
Attorneys for Plaintiff California
Consortium for Agricultural Export, LLC

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ORDER

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Good cause appearing, the above Stipulation is accepted, adopted and made the Order of
this Court.
IT IS SO ORDERED.

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Dated:

April 22, 2014

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND ORDER TO EXTEND DEADLINES AND PRETRIAL CONFERENCE

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STIPULATION AND ORDER TO EXTEND DEADLINES AND PRETRIAL CONFERENCE