SOURCiS, Inc. v. Bravo Development Group, LLC

Filing 17

STIPULATION and ORDER MODIFYING ORDER REQUIRING JOINT STATUS REPORT signed by District Judge Troy L. Nunley on 10/15/15, ORDERING that paragraph 4 of the Order Requiring Joint Status Report is modified as follows: (a) all parties named in the First Amended Complaint shall participate in a Fed. R. Civ. P. 26(f) conference on or before 10/28/2015, and (b) the parties shall file a Joint Status Report on or before 11/12/2015. (Kastilahn, A)

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law corporation

weintraub tobin chediak coleman grodin

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Henry M. Burgoyne, III, State Bar No. 203748
BURGOYNE LAW GROUP
870 Market Street, Suite 985
San Francisco, California 94102
[phone] – Tel.
[phone] – Facsimile
Attorneys for Plaintiff SOURCIS, Inc.
James Kachmar, State Bar No. 216781
weintraub tobin chediak coleman grodin
law corporation

400 Capitol Mall, 11th Floor
Sacramento, CA 95814
[phone] – Main
[phone] – Facsimile
Attorneys for Defendant
BRAVO DEVELOPMENT GROUP, INC.
Robert D. Swanson, State Bar No. 162816
Michael E. Chase, State Bar No. 214506
BOUTIN JONES INC.
555 Capitol Mall, Suite 1500
Sacramento, CA 95814-4603
Attorneys for Defendant DEREK C. DECKER

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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SOURCIS, INC, a California corporation,

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Plaintiff,
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v.
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BRAVO DEVELOPMENT GROUP, INC., a )
California corporation; et al.,
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Defendants.
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Case No.: 2:15-cv-01588-TLN-KJN
STIPULATION AND ORDER MODIFYING
ORDER REQUIRING JOINT STATUS
REPORT
Complaint Filed: July 23, 2015
FAC Filed: September 18, 2015

Plaintiff SOURCIS, INC. (“Plaintiff”), Defendant Bravo Development Group, Inc.

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Stip. & Order Modifying Order
Requiring Joint Status Report

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(“Bravo”) and Defendant Derek C Decker (“Decker”), by and through their counsel of

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record, hereby submit the following stipulation and [proposed] Order to modify the

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Order Requiring Joint Status Report (Dckt. # 2) to extend the time for all parties named in

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the First Amended Complaint to conduct a joint Fed. R. Civ. P. 26(f) conference and

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submit a joint status report that includes the Rule 26(f) discovery plan as follows:

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WHEREAS, Plaintiff filed the Complaint (Dckt. # 1) in this matter on July 23, 2015,
and asserted claims against Bravo only;
WHEREAS, Bravo filed a motion to dismiss pursuant to Fed. R. Civ. P. 12(b)(6) on
August 28, 2015 (Dckt. # 6);
WHEREAS, Plaintiff filed the First Amended Complaint (Dckt. # 7) on September 18,
2015, which in addition to asserting claims against Bravo, alleged claims against Decker;
WHEREAS, Plaintiff served the First Amended Complaint on Decker on September

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28, 2015 (Dckt. # 10), and Decker has yet to file a responsive pleading or motion in this

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matter;

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WHEREAS, counsel for Plaintiff and Bravo conducted a conference pursuant to Fed.

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R. Civ. P. 26(f) on September 29, 2015, during which they agreed to exchange their Initial

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law corporation

weintraub tobin chediak coleman grodin

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Disclosures on or before October 13, 2015 and that Bravo would have until October 12,

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2015, in which to file a responsive pleading to the First Amended Complaint;

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WHEREAS, Decker’s counsel filed a notice of appearance on October 8, 2015;

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WHEREAS, Plaintiff and Bravo believe it will be in the interests of the Court and all

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parties to conserve judicial resources by having all parties participate in a further Fed. R.

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Civ. P. 26(f) conference and submit a single Joint Status Report as required;

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WHEREAS, counsel for all parties have agreed to conduct a further Fed. R. Civ. P.
26(f) conference on October 28, 2015;

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WHEREAS, Plaintiff and Bravo anticipate that a Joint Status Report, including all

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parties named in the First Amended Complaint, can be prepared and submitted to the

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Court within 14 days thereof, or no later than November 12, 2015 (November 11 th being a

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Federal Holiday);

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Stip. & Order Modifying Order
Requiring Joint Status Report

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WHEREAS, the parties agree that as a result of Plaintiff and Bravo’s September 29,
2015 Fed. R. Civ. P. 26(f) conference, discovery is open as between Plaintiff and Bravo;
THEREFORE, Plaintiff and Bravo, by and through their counsel of record, stipulate
that the Court enter an Order as follows:
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Paragraph 4 of the Order Requiring Joint Status Report is modified as

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follows: (a) all parties named in the First Amended Complaint shall participate in a Fed. R.

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Civ. P. 26(f) conference on or before October 28, 2015, and (b) the parties shall file a Joint

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Status Report on or before November 12, 2015.

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IT IS SO STIPULATED.
Dated: October 12, 2015

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By:

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Dated: October 12, 2015

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Dated: October 12, 2015

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/s/ - Michael E. Chase
Robert D. Swanson
Michael E. Chase

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BOUTIN JONES INC.
By:

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/s/ - James Kachmar
James Kachmar
Attorneys for Defendant Bravo Development
Group, Inc.

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/s/ Henry M. Burgoyne
Henry M. Burgoyne, III
Attorneys for Plaintiff Sourcis, Inc.

WEINTRAUB TOBIN CHEDIAK COLEMAN GRODIN
Law Corporation
By:

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law corporation

weintraub tobin chediak coleman grodin

BURGOYNE LAW GROUP

Attorneys for Defendant Derek C. Decker
IT IS SO ORDERED.
Dated: October 15, 2015

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Troy L. Nunley
United States District Judge

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Stip. & Order Modifying Order
Requiring Joint Status Report