Meyer Manufacturing Company Limited v. Telebrands Corp.

Filing 20

STIPULATION and ORDER signed by Judge Lawrence K. Karlton on 2/9/2012 ORDERING Initial Scheduling Conference Reset for 4/30/2012 at 02:00 PM in Courtroom 4 (LKK) before Judge Lawrence K. Karlton. (Reader, L)

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1 2 3 4 5 6 7 8 9 ROPERS, MAJESKI, KOHN & BENTLEY Neil A. Smith, Esq. (SBN 63777) 50 West San Fernando Street, Suite 1400 San Jose, CA 95113-2429 Telephone: (408) 287-6262 Facsimile: (408) 918-4501 Email: nsmith@rmkb.com OF COUNSEL: COOPER & DUNHAM LLP Peter D. Murray, Esq. (Pro Hac Vice Pending) Robert T. Maldonado, Esq. (Pro Hac Vice Pending) Hindy Dym, Esq. (Pro Hac Vice Pending) 30 Rockefeller Plaza New York, New York 10112 Telephone: (212) 278-0509 Facsimile: (212) 391-0525 Email: rmaldonado@cooperdunham.com 10 11 12 13 14 15 16 17 18 19 20 Attorneys for Defendant TELEBRANDS CORP., a New Jersey Corporation HOLLAND & KNIGHT LLP R. David Donoghue, Esq. (SBN 205730) (Counsel for Service) 131 South Dearborn Street, 30th Street Chicago, Illinois 60603 Telephone: (312) 263-3600 Facsimile: (312) 263-6666 Email: david.donoghue@hklaw.com HOLLAND & KNIGHT LLP Matthew P. Vafidis (SBN 1003578) 50 California Street, 28th Floor San Francisco, CA 94111 Telephone: (415) 743-6900 Facsimile: (415) 743-6910 Email: matthew.vafidis@hklaw.com Attorneys for Plaintiff MEYER MANUFACTURING COMPANY LIMITED 21 UNITED STATES DISTRICT COURT 22 EASTERN DISTRICT OF CALIFORNIA - SACRAMENTO DIVISION 23 24 25 MEYER MANUFACTURING COMPANY LIMITED, a Hong Kong Corporation, 26 Plaintiff, 27 v. CASE NO. 2:11-cv-03153 LKK-DAD STIPULATION AND ORDER REQUESTING THAT THE COURT POSTPONE INITIAL SCHEDULING CONFERENCE, AND OTHER DATES, PENDING A DECISION BY THE COURT ON MOTION TO TRANSFER 28 Stipulation Postponing Case Management Conference RC1/6312891.1/RL3 -1- CASE NO. 2:11-CV-03153 LKK-DAD 1 2 TELEBRANDS CORP., a New Jersey Corporation, 3 Defendant. 4 5 Plaintiff MEYER MANUFACTURING COMPANY LIMITED and Defendant 6 TELEBRANDS CORP., by their counsel, hereby stipulate, agree, and request, subject to approval 7 by the Court, to postpone the parties' deadline for submitting their Status Reports, currently set 8 for February 7, 2012, as well as the Status Conference, currently set for February 21, 2012, at 9 2:00 p.m., to seven (7) and twenty-one (21) days, respectively, following a decision by the Court 10 on Defendant's pending Motion to Transfer, currently set for hearing on March 12, 2012, or such 11 other date(s) as may be set by the Court, pursuant to the proposed Order form below. 12 Defendant currently has pending before the Court a Motion to Transfer this action to the 13 United States District Court for New Jersey, which motion is scheduled to be heard by this Court 14 on March 12, 2012, at 10:00 a.m. 15 Without prejudice to either party, the parties jointly request that this Court postpone the 16 February 7, 2012 Status Report deadline, the February 21, 2012 Case Management Conference, 17 and other deadlines and obligations relating thereto, including the time for the parties to exchange 18 initial disclosures pursuant to Rule 26 of the Federal Rules of Civil Procedure, to dates following 19 a decision by the Court on the pending Motion to Transfer. 20 Should this action be transferred, then the initial scheduling conference, case management 21 meetings, filing, and hearings can be held in the transferee Court. The briefing and decision on 22 the Motion to Transfer, may also affect case management, so in the interests of justice and 23 efficiency, the parties jointly request that the Court approve the [Proposed] Order below. 24 Dated: February 7, 2012 HOLLAND & KNIGHT LLP 25 By: /s/ R. David Donoghue R. DAVID DONOGHUE Attorneys for Plaintiff MEYER MANUFACTURING COMPANY LIMITED 26 27 28 Stipulation Postponing Case Management Conference RC1/6312891.1/RL3 -2- CASE NO. 2:11-CV-03153 LKK-DAD 1 Dated: February 7, 2012 COOPER & DUNHAM LLP 2 ROPERS, MAJESKI, KOHN & BENTLEY 3 4 By: /s/ Neil A. Smith NEIL A. SMITH Attorneys for Defendant TELEBRANDS CORP. 5 6 7 8 ORDER POSTPONING CASE MANAGEMENT 9 Plaintiff and defendant having jointly requested that the Court postpone the Initial 10 Scheduling Conference, and the dates and meetings relating thereto, to a date following the 11 decision by the Court on a pending Motion to Transfer this action to New Jersey, and the Court 12 having approved the stipulation of the parties, 13 14 IT IS HEREBY ORDERED that the Initial Scheduling Conference in this action shall be continued to April 30, 2012 at 2:00 p.m. 15 Dates for meeting of counsel, and filing Case Management/Scheduling Statements and 16 Orders shall be proportionately moved back the same number of days as the Initial Scheduling 17 Conference, set by the Court. 18 19 Dated: February 9, 2012 20 21 22 23 24 25 26 27 28 Stipulation Postponing Case Management Conference RC1/6312891.1/RL3 -3- CASE NO. 2:11-CV-03153 LKK-DAD

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