Verma, et al. v. Okev, et al.

Filing 51

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr., on 7/28/14 ORDERING that the time for all parties to complete non-expert discovery is EXTENDED to 10/21/2014. (Kastilahn, A)

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STIMMEL, STIMMEL & SMITH
A Professional Corporation
LEE D. STIMMEL, ESQ. (State Bar No. 58405)
e-mail: [e-mail]
155 Montgomery Street, 12th Floor
San Francisco, California 94104-3973
Telephone: [phone]
Facsimile: [phone]
ARCHER NORRIS LLP
SETH J. SCHWARTZ (State Bar No. 103357)
e-mail: [e-mail]
2033 North Main Street, Suite 800
Walnut Creek, CA 94596
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs and Cross-Defendants
KRISTI VERMA, VISHAL VERMA AND ZENTEK
CORPORATION, a California Corporation,

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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KRISTI VERMA, et al.
Plaintiffs,

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v.

Defendants.
EFRAT OKEV, et al.
Counterclaimants,

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STIPULATION AND ORDER TO
EXTEND CUTOFF FOR DISCOVERY
AND DISCOVERY MOTION

EFRAT OKEV, et al.

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Case No. 2:13-CV-00865-MCE-EFB

v.
KRISTI VERMA, et al,
Counterdefendants.

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STIPULATION TO EXTEND CUTOFF FOR DISCOVERY
AND DISCOVERY MOTION
S0461004/1865786-1

Case No. 2:13-CV-00865-MCE-EFB

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Plaintiffs and Counterdefendants Kristi Verma, Vishal Verma, and Zentek Corporation

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(collectively, “Plaintiffs”) requested a 60-day extension of time to hold open non-expert

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discovery. Defendants and counterclaimants are amenable to such an extension.

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The parties attended a settlement conference in this lawsuit for breach of fiduciary duty,

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misappropriation of corporate assets and other related causes of action, in addition to a cross-

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complaint for involuntary corporate dissolution and indemnification, on June 9, 2014. The case

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did not settle at that time. The case involves voluminous and extensive electronic discovery being

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sought by both sides. There are numerous witnesses; the defendants live in St. Louis, Missouri.

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Counsel are in the process of exchanging documents, meeting and conferring re documents and

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working to set the parties’ depositions, including those in the Midwest. The parties need an

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opportunity to analyze the documents before going forward with the depositions. Thousands of

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pages of documents are involved. Further, it may be necessary to notice additional depositions of

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several other witnesses, also located in the Midwest, depending on the parties’ deposition

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testimony.

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Defendants have produced thousands of pages of imaged documents that are being

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reviewed and in excess of 51,000 electronic files and may produce additional files. Plaintiffs are

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in the process of producing significant volumes of ESI. Each side is working with computer

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consultants to expedite the discovery of ESI and to minimize the cost. The parties have worked

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diligently to identify the relevant and responsive discovery materials, including ESI, and are

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working cooperatively to prepare the case for trial.

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Counsel have agreed on a 60 day discovery extension. This extension will not interfere
with any of the court’s pre—trial dates.

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Accordingly, pursuant to Rule 16(b) and Rule 29 of the Federal Rules of Civil Procedure,

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the parties, by and through their undersigned counsel of record, hereby collectively agree and

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stipulate to the following:

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1.

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October 21, 2014.

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///

The time for all parties to complete non-expert discovery shall be extended to

STIPULATION TO EXTEND CUTOFF FOR DISCOVERY
AND DISCOVERY MOTION
S0461004/1865786-1

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Case No. 2:13-CV-00865-MCE-EFB

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Dated: July 21, 2014

ARCHER NORRIS, PLC

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By:

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Dated: July 21, 2014

/s/ SETH J. SCHWARTZ
ORIGINAL SIGNATURE ON ECF-SUBMITTED
VERSION
Seth J. Schwartz
Co-Counsel for Plaintiffs and Counterdefendants
Kristi Verma, Vishal Verma, and Zentek Corporation

PFEIFFER FITZGIBBON & ZIONTZ LLP

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By:

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/s/ THOMAS N. FITZGIBBON
Thomas N. FitzGibbon
Attorneys for Defendants and Counterclaimants
Efrat Okev and Lloyd Burton

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ORDER

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IT IS SO ORDERED.
Dated: July 28, 2014

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STIPULATION TO EXTEND CUTOFF FOR DISCOVERY
AND DISCOVERY MOTION
S0461004/1865786-1

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Case No. 2:13-CV-00865-MCE-EFB