Thermogenesis Corp. v. Origen Biomedical, Inc.

Filing 21

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr. on 3/19/2014 ORDERING 20 that the Parties' request for additional time to submit the Joint Status Report and Discovery Plan in this matter is GRANTED. The Parties Joint Status Report and Discovery Plan must now be filed with the Court on or before 3/21/2014. (Reader, L)

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THOMAS A. WOODS (SB #210050)
[e-mail]
STOEL RIVES LLP
500 Capitol Mall, Suite 1600
Sacramento, CA 95814
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
ORIGEN BIOMEDICAL, INC.
ANDREA M. MILLER (SB #88992)
[e-mail]
NAGELEY, MEREDITH & MILLER, INC.
8801 Folsom Blvd., Suite 172
Sacramento, CA 95826
Telephone: [phone]
Facsimile: [phone]
JOANNA M. ESTY (SB #147903)
[e-mail]
MAJESTY LAW GROUP PLC
6080 Center Drive, 6th Floor
Los Angeles, CA 90045
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
THERMOGENESIS CORP.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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THERMOGENESIS CORP.,

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Plaintiff,
v.
ORIGEN BIOMEDICAL, INC.,

Case No. 2:13-CV-02619-MCE-DAD
STIPULATION AND ORDER FURTHER
EXTENDING TIME FOR PARTIES TO
SUBMIT THE JOINT STATUS REPORT
[Fed. R. Civ. P. 6; Local Rule 144]

Defendant.

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S T O E L R I V E S LLP
ATTORNEYS AT LAW
SACRAMENTO

STIPULATION FURTHER EXTENDING TIME
TO SUBMIT JOINT STATUS REPORT
75807835.1 0053535- 00001

2:13-CV-02619-MCE-DAD

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WHEREAS on March 10, 2014 the Court issued its Order allowing Plaintiff

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ThermoGenesis Corporation (“Plaintiff”) and Defendant OriGen Biomedical, Inc. (“Defendant”)

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until March 17, 2014 to submit their Joint Status Report and Discovery Plan called for by the

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Court’s December 18, 2013 Order Requiring Joint Status Report (“Order”) and Federal Rule of

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Civil Procedure 26(f) (“Rule 26(f)”).

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WHEREAS on March 14, 2014, Defendants timely filed their Motion to Dismiss
Plaintiff’s Complaint in part.

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WHEREAS from March 14 through March 17, 2014, counsel for the Parties met and

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conferred in writing and telephonically on all issues required by the Order and Rule 26(f). A

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draft of the Joint Status Report and Discovery Plan incorporating all: proposed dates, items for

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inclusion in the discovery plan, and all other items required by the Order and Rule 26(f) is in the

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process of being prepared.

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WHEREAS, at the time of the preparation of this STIPULATION, the Parties require

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additional time to finalize the Joint Status Report and Discovery Plan because there were several

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items for inclusion in the document that counsel for the Parties are unable to come to agreement

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on. Also, the final Joint Status Report is being reviewed and edited across time zones, with one

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counsel being in Maryland, on business, and in court hearings in Maryland this week.

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WHEREAS a brief extension of time will enable the Parties to work together to submit

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one Joint Status Report and proposed Discovery Plan in compliance with the Order (albeit with

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certain subsections specific to the individual parties detailed therein), rather than two slightly

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different Status Reports, possibly filed at slightly different times.

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Plaintiff and Defendant, by and through their counsel of record, therefore STIPULATE to

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and respectfully request a brief, additional extension of time for the parties to submit the Joint

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Status Report and proposed Discovery Plan until on or before Friday, March 21, 2014.

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S T O E L R I V E S LLP
ATTORNEYS AT LAW
SACRAMENTO

STIPULATION FURTHER EXTENDING TIME
TO SUBMIT JOINT STATUS REPORT
75807835.1 0053535- 00001

-1-

2:13-CV-02619-MCE-DAD

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DATED: March 17, 2014

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STOEL RIVES LLP

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By: /s/ Thomas A. Woods
THOMAS A. WOODS
Attorneys for Defendant
ORIGEN BIOMEDICAL, INC.

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DATED: March 17, 2014

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MAJESTY LAW GROUP PLC

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By: /s/ Joanna M. Esty (as authorized 03-17-14)
JOANNA M. ESTY
Attorneys for Plaintiff
THERMOGENESIS CORP.

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ORDER

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Based upon the foregoing Stipulation of the Parties and for good cause appearing

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therefore, IT IS HEREBY ORDERED that the Parties’ request for additional time to submit the

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Joint Status Report and Discovery Plan in this matter is GRANTED. The Parties Joint Status

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Report and Discovery Plan must now be filed with the Court on or before March 21, 2014.

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IT IS SO ORDERED.
Dated: March 19, 2014

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S T O E L R I V E S LLP
ATTORNEYS AT LAW
SACRAMENTO

STIPULATION FURTHER EXTENDING TIME
TO SUBMIT JOINT STATUS REPORT
75807835.1 0053535- 00001

-2-

2:13-CV-02619-MCE-DAD