Meyer Manufacturing Company Limited v. Telebrands Corp.
Filing
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STIPULATION and ORDER 32 to postpone deadline and related dates signed by Judge Lawrence K. Karlton on 4/11/2012. Initial Scheduling Conference is CONTINUED to 5/29/2012 at 2:00 PM in Courtroom 4 (LKK). Dates for meeting counsel, initial disclosure, and filing of Case Management / Status Reports, shall be proportionately moved back same number of days as Scheduling Conference. (Marciel, M)
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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)
Robert T. Maldonado, Esq. (Pro Hac Vice)
Hindy Dym, Esq. (Pro Hac Vice)
30 Rockefeller Plaza
New York, New York 10112
Telephone:
(212) 278-0509
Facsimile:
(212) 391-0525
Email:
rmaldonado@cooperdunham.com
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Attorneys for Defendant
TELEBRANDS CORP., a New Jersey Corporation
HOLLAND & KNIGHT LLP
R. David Donoghue, Esq. (SBN 205730) (Counsel for Service)
Michael A. Grill, Esq. (Pro Hac Vice)
131 South Dearborn Street, 30th Street
Chicago, Illinois 60603
Telephone: (312) 263-3600
Facsimile: (312) 263-6666
Email: david.donoghue@hklaw.com
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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
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Attorneys for Plaintiff
MEYER MANUFACTURING COMPANY LIMITED
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA - SACRAMENTO DIVISION
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MEYER MANUFACTURING
COMPANY LIMITED, a Hong Kong
Corporation,
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Plaintiff,
v.
CASE NO. 2:11-cv-03153 LKK-DAD
STIPULATION AND ORDER REQUESTING THE
COURT TO POSTPONE STATUS REPORT
DEADLINE, INITIAL STATUS CONFERENCE,
AND RELATED DATES, UNTIL AFTER
DEFENDANT FILES ITS ANSWER
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Stipulation Postponing Case
Management Conference
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CASE NO. 2:11-CV-03153 LKK-DAD
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TELEBRANDS CORP., a New Jersey
Corporation,
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Defendant.
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Plaintiff MEYER MANUFACTURING COMPANY LIMITED and Defendant
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TELEBRANDS CORP., by their counsel, hereby stipulate, agree, and request, subject to approval
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by the Court, to postpone the parties' deadline for submitting their Status Report, currently set for
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April 16, 2012, as well as the Status Conference, currently set for April 30, 2012, at 2:00 p.m.,
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until May 29, 2012, at 2:00 p.m., pursuant to the proposed Order form below.
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On April 9, 2012, the Court denied Defendant's Motion to Transfer this action to the
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United States District Court for New Jersey as well as Defendant's Motion to Extend the Time to
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Answer the Complaint. The Court ordered Defendant to file its Answer by April 16, 2012.
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Immediately prior to the Court's ruling, the parties had agreed to, and were in the process of
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finalizing a stipulation to postpone the initial Status Conference and related deadlines until after
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the Court ruled and after Defendant filed its Answer.
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As currently scheduled, the parties' Status Report is due on April 16, 2012, the same day
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as Defendant's Answer is now due. But Defendant's Answer and any counterclaims will
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undoubtedly affect case management, as well as the scope of the parties' conference pursuant to
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Federal Rule of Civil Procedure 26(f). Therefore, without prejudice to either party, the parties
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jointly request that this Court postpone the April 16, 2012 Status Report deadline, along with the
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April 30, 2012 Case Management Conference, and other deadlines and obligations relating
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thereto, including the time for the parties to exchange initial disclosures pursuant to Federal Rule
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of Civil Procedure 26(a), in order to allow the parties time to evaluate Defendant's Answer, and to
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hold a meaningful Rule 26(f) conference thereafter, prior to submitting their Status Report and
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serving initial disclosures.
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WHEREFORE, in the interests of justice and efficiency, the parties jointly request that the
Court approve the [Proposed] Order below.
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Stipulation Postponing Case
Management Conference
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CASE NO. 2:11-CV-03153 LKK-DAD
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Dated: April 10, 2012
HOLLAND & KNIGHT LLP
By: /s/ Michael A. Grill
R. DAVID DONOGHUE
MICHAEL A. GRILL
Attorneys for Plaintiff
MEYER MANUFACTURING COMPANY
LIMITED
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Dated: April 10, 2012
COOPER & DUNHAM LLP
ROPERS, MAJESKI, KOHN & BENTLEY
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By: /s/ Neil A. Smith
NEIL A. SMITH
Attorneys for Defendant
TELEBRANDS CORP.
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ORDER POSTPONING CASE MANAGEMENT
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Plaintiff and Defendant having jointly requested that the Court postpone the Initial
Scheduling Conference, and the dates and meetings relating thereto, to allow sufficient time for
the parties to meet and confer and to submit their initial status report following Defendant's filing
of its Answer, which must be filed on April 16, 2012,
IT IS HEREBY ORDERED that the Initial Scheduling Conference in this action shall be
scheduled on May 29, 2012, at 2:00 p.m.
Dates for meeting of counsel, initial disclosures, and the filing of Case Management/
Status Reports, shall be proportionately moved back the same number of days as the Initial
Scheduling Conference, as set by the Court.
Dated: April 11, 2012
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Stipulation Postponing Case
Management Conference
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CASE NO. 2:11-CV-03153 LKK-DAD
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