Noble Systems Corp. v. Howell

Filing 14

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr on 7/2/09 ORDERING that the parties must confer and develop a proposed discovery plan no later than 7/20/09; the parties must file a Joint Status Report no later than 7/27/09; and, A Status (Pretrial Scheduling Conference) will be held on 8/10/09 at 9:00 a.m. (Becknal, R)

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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 Rochelle L. Wilcox (State Bar No. 197790) E-mail: rochellewilcox@dwt.com DAVIS WRIGHT TREMAINE LLP 865 South Figueroa Street, Suite 2400 Los Angeles, California 90017 Telephone: (213) 633-6800 Facsimile: (213) 633-6899 Attorneys for Plaintiff NOBLE SYSTEMS CORP. UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION NOBLE SYSTEMS CORP., Plaintiff, v. CHRIS HOWELL d/b/a IMPACT MARKETING, Defendant. Case No. 2:09-cv-00749 [Assigned to The Honorable Garland E. Burrell, Jr. Courtroom 10] SECOND STIPULATED REQUEST FOR: (1) EXTENSION OF TIME FOR PARTIES TO MEET AND CONFER AND SUBMIT A JOINT STATUS REPORT; AND (2) CONTINUANCE OF STATUS (PRE-TRIAL SCHEDULING) CONFERENCE CURRENTLY SCHEDULED FOR JULY 27, 2009 [PROPOSED] ORDER THEREON [Local Rules 6-144, 16-240] Original Complaint Filed: March 16, 2009 13061265_1.DOC 1 SECOND STIPULATED REQUEST FOR EXTENSION OF TIME TO MEET AND FILE JOINT STATUS REPORT; CONTINUANCE OF STATUS (PRE-TRIAL) SCHEDULING CONFERENCE; [PROPOSED] ORDER DWT 13061265v1 0089263-000001 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 COME NOW Plaintiff Noble Systems Corp. ("Noble") and Defendant Chris Howell d/b/a Impact Marketing ("Howell"), through their respective counsel of record, and pursuant to Local Rules 6-144 and 16-240, do hereby represent to the Court and stipulate as follows: 1. Pursuant to this Court's Order Setting Status (Pretrial Scheduling) Conference, issued on March 18, 2009, and the Court's Order entered on June 11, 2009, extending the deadlines established by the Order Setting Status (Pretrial Scheduling) Conference, the following deadlines are currently pending in this matter: a. b. 2009; and, c. 2. A Status (Pretrial Scheduling) Conference is scheduled to be held on July 27, 2009, at 9:00 a.m. The parties continue to be engaged in settlement negotiations, having made significant progress, and although they have not yet reached agreement they continue to be optimistic about the possibility of settling this matter; 3. Lead counsel for Noble is out of the country and unavailable during the week of July 1, 2009, and lead counsel for Howell is traveling and unavailable on July 6, 7, 8, 13 and 14, 2009; 4. The parties would like to continue to explore the possibility of settlement before they are required to spend the time necessary to prepare a proposed discovery plan and Joint Status Report; 5. The parties therefore request that the current deadlines be extended, and the Status (Pretrial Scheduling) Conference continued, for at least two weeks. They propose, and respectfully request, the following schedule: 13061265_1.DOC The parties must confer and develop a proposed discovery plan The parties must file a Joint Status Report no later than July 13, no later than July 6, 2009; 2 SECOND STIPULATED REQUEST FOR SECOND EXTENSION OF TIME FOR CHRIS HOWELL d/b/a IMPACT MARKETING TO RESPOND TO COMPLAINT; [PROPOSED] ORDER DWT 13061265v1 0089263-000001 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 13061265_1.DOC a. b. 2009; and, c. The parties must confer and develop a proposed discovery plan The parties must file a Joint Status Report no later than July 27, A Status (Pretrial Scheduling Conference) will be held on DAVIS WRIGHT TREMAINE LLP By:/s/ Rochelle L. Wilcox Rochelle L. Wilcox Attorneys for Plaintiff Noble Systems Corp. no later than July 20, 2009; August 10, 2009 at 9:00 a.m. DATED: July 2, 2009 DATED: July 2, 2009 RUSS, AUGUST & KABAT By:/s/ Marc A. Fenster (as authorized on 7/2/09) Marc A. Fenster Attorneys for Defendant Chris Howell d/b/a Impact Marketing [PROPOSED] ORDER It is so ordered. Dated: July 2, 2009 GARLAND E. BURRELL, JR. United States District Judge 3 SECOND STIPULATED REQUEST FOR SECOND EXTENSION OF TIME FOR CHRIS HOWELL d/b/a IMPACT MARKETING TO RESPOND TO COMPLAINT; [PROPOSED] ORDER DWT 13061265v1 0089263-000001

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