Team One Networking v. Eatmon et al

Filing 38

STIPULATION and ORDER signed by Judge William B. Shubb on 8/26/10 ORDERING completion of all percipient discovery set for 11/15/10; mediation completed by 12/17/10; disclosure of experts set for 12/31/10; disclosure of supplemental experts set for 1/ 14/11; expert discovery completed by 2/22/11; pretrial conference statement due by 2/26/11; pretrial conference set for 3/8/11 at 2:00 PM before Judge William B. Shubb; jury trial set for 3/22/11 at 9:00 AM in Courtroom 5 (WBS) before Judge William B. Shubb; and the Counterclaim of Dan Lockwood is amended to include additional claims for relief.(Carlos, K)

Team One Networking v. Eatmon et al

Doc. 38

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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 CONTINUE THE TRIAL DATE, MODIFY THE STATUS (PRETRIAL SCHEDULING) ORDER AND AMEND THE COUNTERCLAIM OF DAN LOCKWOOD 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. DAN LOCKWOOD, Counterclaimant, v. TEAM ONE NETWORKING, a California Corporation; Counterdefendant.

The Honorable William B. Shubb

WHEREAS, the parties agreed to modify the Court's August 5, 2009 Status (Pretrial Scheduling) Order ("Scheduling Order") extending deadlines for the original expert witness disclosure, the supplemental expert witness disclosure, and the deadline for completion of discovery. The Court approved the stipulation on March 4, 2010.

STIPULATION AND ORDER TO CONTINUE THE TRIAL DATE, MODIFY THE STATUS (PRETRIAL SCHEDULING) ORDER AND AMEND THE COUNTERCLAIM OF DAN LOCKWOOD

Dockets.Justia.com

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

WHEREAS, in April 2010, the parties further agreed to modify the Scheduling Order extending discovery and related deadlines closer to the trial date. The Court approved the stipulation on May 5, 2010. WHEREAS, defendant and counterclaimant Lockwood has determined as a result of further review of discovery responses and other documentation, that additional claims for relief exist relating to the employment relationship between Lockwood and Team One Networking that should be brought in this action, Lockwood's Counterclaim should be amended to add such additional claims for relief in the form of a First Amended Counterclaim. WHEREAS, the parties continue to exchange documents responsive to the discovery requests, which exchange has been much slower than expected due to the technical nature of the electronic documentation. The parties wish to complete discovery in November in order to conduct a

meaningful mediation in December 2010. The delays, coupled with unavailability for depositions and an earlier trial date due to conflicting trial obligations of counsel, have necessitated the need to move the trial date to March 22, 2011. The parties hereby agree that defendant and counterclaimant Dan Lockwood may file his First Amended Counterclaim, a copy of which is attached hereto as Exhibit A. The parties further agree to modify the Scheduling Order in the following ways and ask that the Court approve this modification: COMPLETION OF ALL PERCIPIENT DISCOVERY MEDIATION TO BE COMPLETED BY DISCLOSURE OF EXPERTS DISCLOSURE OF SUPPLEMENTAL EXPERTS EXPERT DISCOVERY COMPLETED DISPOSITIVE MOTION HEARING DEADLINE PRETRIAL CONFERENCE STATEMENT PRETRIAL CONFERENCE TRIAL IT IS SO STIPULATED.
STIPULATION AND ORDER TO CONTINUE THE TRIAL DATE, MODIFY THE STATUS (PRETRIAL SCHEDULING) ORDER AND AMEND THE COUNTERCLAIM OF DAN LOCKWOOD

NOVEMBER 15, 2010 DECEMBER 17, 2010 DECEMBER 31, 2010 JANUARY 14, 2011 FEBRUARY 22, 2011 FEBRUARY 22, 2011 FEBRUARY 26, 2011 MARCH 8, 2011 MARCH 22, 2011

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

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 CONTINUE THE TRIAL DATE, MODIFY THE STATUS (PRETRIAL SCHEDULING) ORDER AND AMEND THE COUNTERCLAIM OF DAN LOCKWOOD

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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: August 26, 2010

STIPULATION AND ORDER TO CONTINUE THE TRIAL DATE, MODIFY THE STATUS (PRETRIAL SCHEDULING) ORDER AND AMEND THE COUNTERCLAIM OF DAN LOCKWOOD

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