Team One Networking v. Eatmon et al

Filing 36

STIPULATION and ORDER 35 for modification of 25 Status (Pretrial Scheduling) Order signed by Judge William B. Shubb on 5/5/2010. Disclosure of Expert Witnesses is now due 8/20/2010 and Disclosure of Supplemental Experts is due 9/3/2010. Completion of all Discovery shall submitted by 9/17/2010. Dispositive Motion Hearing deadline is now set for 10/31/2010. The Final Pretrial Conference and Trial dates will remain unchanged. (Marciel, M)

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PALMER KAZANJIAN WOHL HODSON LLP 520 Capitol Mall, Suite 600 Sacramento, CA 95814 916.442.3552

Christopher Wohl, SBN: 170280 Jennifer L. McQuarrie, SBN: 191730 PALMER KAZANJIAN WOHL HODSON, LLP 520 Capitol Mall, Suite 600 Sacramento, California 95814 Phone: [phone] Attorneys for Plaintiff and Counterdefendant, TEAM ONE NETWORKING UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA -oooOoooTEAM ONE NETWORKING, a California Corporation; v. Plaintiffs, STIPULATION AND ORDER TO MODIFY THE STATUS (PRETRIAL SCHEDULING) ORDER RE DISCOVERY CASE NO. 2:09-cv-00903

JASON EATMON, individually; DAN LOCKWOOD, individually, DEVELOPMENT GROUP, INC. a California corporation,; and, DOES 1 through 10, inclusive, Defendants.

The Honorable William B. Shubb DAN LOCKWOOD, Counterclaimant, v. TEAM ONE NETWORKING, a California Corporation; Counterdefendant.
The Court's August 5, 2009 Status (Pretrial Scheduling) Order originally established an expert witness disclosure date of February 12, 2010, a supplemental expert witness disclosure date of April 2, 2010, and a deadline for completion of discovery of May 28, 2010, which would be inclusive of all expert witness discovery and discovery motions.

STIPULATION AND ORDER TO MODIFY THE STATUS (PRETRIAL SCHEDULING) ORDER

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PALMER KAZANJIAN WOHL HODSON LLP 520 CAPITOL MALL, SUITE 600 SACRAMENTO, CA 95814 916.442.3552

The parties previously submitted to the Court a Stipulation modifying the deadlines relating to expert disclosure and expert discovery. The parties continue to conduct written discovery but have not yet begun proceeding with all necessary depositions. Due to the technical nature of this case, the speed with which the parties have been able to produce electronic documentation has been slower than expected. Despite the delays, the parties have been diligent in their efforts. In light of these delays, it is apparent to the parties that it is not realistic that the depositions of percipient witnesses will be completed until July, with expected expert discovery thereafter. In order to provide the parties sufficient time to prepare for the November 30, 2010 trial date, the parties propose to amend the schedule to provide for the following dates: DISCLOSURE OF EXPERTS DISCLOSURE OF SUPPLEMENTAL EXPERTS AUGUST 20, 2010 SEPTEMBER 3, 2010

COMPLETION OF ALL DISCOVERY (INCLUDING EXPERT) SEPTEMBER 17, 2010 DISPOSITIVE MOTION HEARING DEADLINE OCTOBER 31, 2010

All other deadlines (final pretrial conference and trial) will remain unchanged. IT IS SO STIPULATED.

CARR, KENNEDY, PETERSON & FROST

Dated:

By:

/s/ Randall Nelson Randall Nelson, Esq. Attorneys for Defendants and Counterclaimants Jason Eatmon, Dan Lockwood and Development Group, Inc.

PALMER KAZANJIAN WOHL HODSON, LLP

Dated:

By: /s/ Christopher F. Wohl Christopher F. Wohl Attorneys for Plaintiff and Counterdefendant Team One Networking, Inc.

STIPULATION AND ORDER TO MODIFY THE STATUS (PRETRIAL SCHEDULING) ORDER

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PALMER KAZANJIAN WOHL HODSON LLP 520 CAPITOL MALL, SUITE 600 SACRAMENTO, CA 95814 916.442.3552

ORDER Upon the agreement of the parties hereto, and Good Cause appearing IT IS SO ORDERED.

DATED: May 5, 2010

STIPULATION AND ORDER TO MODIFY THE STATUS (PRETRIAL SCHEDULING) ORDER

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