Universal Paragon Corporation et al v. Ingersoll-Rand Company et al

Filing 296

STIPULATION AND ORDER continuing the Case Management Conference to 9/20/2010 at 01:30 PM in Courtroom 12, 19th Floor, San Francisco. Signed by Judge Thelton E. Henderson on 06/10/10. (rbe, COURT STAFF) (Filed on 6/10/2010)

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FICES OF

STUART I. BLOCK (STATE BAR NO. 160688) [e-mail] PERRY S. HUGHES (STATE BAR NO. 167784) [e-mail] COX, CASTLE & NICHOLSON LLP 555 California Street, 10th Floor San Francisco, CA 94104-1513 Telephone: [phone], Facsimile: [phone] Attorneys for Plaintiff UNIVERSAL PARAGON CORPORATION and SUNQUEST PROPERTIES, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA Case No. CV-05-3100 TEH STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER Date: Time: June 14, 2010 1:30 P.M. September 13, 2010 1:30 P.M.

UNIVERSAL PARAGON CORPORATION, a Delaware corporation; and SUNQUEST PROPERTIES, INC., a California corporation, Plaintiffs, vs. INGERSOLL-RAND COMPANY LIMITED, a Bermuda corporation; INGERSOLL-RAND CORPORATION, a New Jersey corporation; SCHLAGE LOCK COMPANY, a California corporation; and TOUCH-PLATE INTERNATIONAL, INC., a California corporation, Defendants. AND RELATED COUNTERCLAIM

Proposed Date: Time:

The parties, Plaintiffs Universal Paragon Corporation and Sunquest Properties, Inc. (collectively "Plaintiffs") and Third Party Defendant Union Pacific Railroad Company, ("Union Pacific"), hereby stipulate, subject to the Court's approval as provided below, to a continuance of the Case Management Conference scheduled for June 14, 2010, so that they can continue in good faith to pursue settlement discussions. On May 13, 2010, the parties had a full day of mediation before the Honorable William L Bettinelli (Ret.). Though the parties were unable to reach a settlement, through

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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER (U.S.D.C. CASE NO. CV-05-3100 TEH)

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Judge Bettinelli they were able to share their respective positions on the facts and law relevant to Plaintiffs' claims. The parties agreed that a further exchange of information was needed to continue with settlement discussions. Plaintiffs are in the process of preparing a brief to Union Pacific to expand on positions expressed during the mediation. Both parties feel that an additional ninety (90) day continuance of the Case Management Conference would be beneficial to allow the parties to continue their settlement discussions. Accordingly, the Parties stipulate to, and request that the Court, continue the Case Management Conference to September 13, 2010, at 1:30 p.m., or such other date and time thereafter that is convenient to the Court so that they can continue to work towards a potential settlement. Respectfully submitted, DATED: June 9, 2010 COX, CASTLE & NICHOLSON LLP

By: /s/ Perry S. Hughes Perry S. Hughes, Attorney for Plaintiffs UNIVERSAL PARAGON CORP. and SUNQUEST PROPERTIES, INC. DATED: June 9, 2010 BARG COFFIN LEWIS & TRAPP LLP

By: /s/ John F. Barg John F. Barg, Attorney for Counter-Defendant Union Pacific Railroad Company IT IS ORDERED that the Case Management Conference scheduled on June 14, 2010, is hereby September 20 continued to _____________________, 2010 at 1:30 pm. No further CMC continuances shall be granted. Dated: June 10 2010 __,

S DISTRICT TE C TA Honorable Thelton E. Henderson

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