Thomas Weisel Partners LLC et al v. BNP Paribas et al

Filing 173

STIPULATION AND ORDER EXTENDING DISCOVERY DEADLINES: Final Dispositive motions/Further Case Management Conference set for 6/14/2010 02:00 PM in Courtroom 15, 18th Floor, San Francisco; Jury Trial continued to 8/17/2010 08:30 AM in Courtroom 15, 18th Floor, San Francisco; Signed by Judge Marilyn Hall Patel on 1/4/2010. (awb, COURT STAFF) (Filed on 1/4/2010)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 GILBERT R. SEROTA (No. 75305) Email: gserota@howardrice.com CLARA J. SHIN (No. 214809) Email: cshin@howardrice.com MICHAEL L. GALLO (No. 220552) Email: mgallo@howardrice.com HOWARD RICE NEMEROVSKI CANADY FALK & RABKIN A Professional Corporation Three Embarcadero Center, 7th Floor San Francisco, California 94111-4024 Telephone: 415/434-1600 Facsimile: 415/217-5910 Attorneys for Plaintiffs THOMAS WEISEL PARTNERS LLC and THOMAS WEISEL INTERNATIONAL PRIVATE LIMITED UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION THOMAS WEISEL PARTNERS LLC, a Delaware limited liability company, and THOMAS WEISEL INTERNATIONAL PRIVATE LIMITED, an Indian company, Plaintiffs, v. BNP PARIBAS, a French corporation, BNP PARIBAS SECURITIES (ASIA) LIMITED, a Hong Kong company, and PRAVEEN CHAKRAVARTY, an individual, Defendants. No. C-07-6198 MHP Action Filed: December 6, 2007 STIPULATED REQUEST FOR ORDER EXTENDING DISCOVERY DEADLINES AND TRIAL DATE AND [PROPOSED] ORDER (L.R. 6-2) Proposed Trial Date: August 17, 2010 STIPULATED REQUEST FOR ORDER EXTENDING DISCOVERY DEADLINES C-07-6198 MHP 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Pursuant to Civil Local Rule 6-2, IT IS HEREBY STIPULATED by and between the parties hereto through their respective attorneys of record that, if the Court approves, the current discovery deadlines in the above-captioned case be extended as set forth below. The stipulation is based on the following: On November 23, 2009, the Court held a discovery hearing and directed the parties to meet and confer on various discovery matters. The parties have met and have made substantial progress towards resolving their outstanding discovery disputes. To permit the completion of discovery, the parties have agreed to further extend the discovery deadlines and trial date. The current schedule has been set in a series of agreements and court orders. On November 18, 2008, the parties in the above-captioned action filed a Discovery Plan pursuant to Federal Rule of Civil Procedure 26(f) setting forth, among other things, discovery deadlines. On February 9, 2009, the parties appeared for a Status Conference and the Court issued Amended Civil Minutes setting discovery deadlines and a trial date. On June 12, 2009, the Court entered an Order granting the stipulated request of the parties to reset the discovery deadlines and trial date in the above-captioned action. On October 5, 2009, the Court entered an Order granting the stipulated request of the parties to reset the discovery deadlines and trial date in the above-captioned action. The parties seek Court approval to further extend the discovery deadlines as follows: 1. The deadline for depositions shall be extended to January 22, 2010 for the following purposes: (a) to depose Plaintiffs' Rule 30(b)(6) representative(s); (b) to complete the deposition of Thomas Weisel; and (c) to complete the deposition of Ted Smarz, if necessary. The parties agree to complete their productions of documents relevant to these depositions at least 10 days prior to these depositions. 2. The deadlines set herein for depositions shall not preclude Plaintiffs from seeking an order from the Court to a take a 30(b)(6) deposition of the BNPP Defendants on the subject of preservation of evidence, including tape recordings, or Defendants from objecting to issuance of such an order on any grounds, including untimeliness and lack of necessity. STIPULATED REQUEST FOR ORDER EXTENDING DISCOVERY DEADLINES C-07-6198 MHP -1- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3. The deadline for exchanging expert reports shall be extended from December 9, 2009 to February 22, 2010. 4. The deadline for exchanging expert rebuttal reports shall be extended from January 11, 2010 to March 22, 2010. 5. 6. June 14, 2010. 7. The trial date shall be moved from May 11, 2010 to August 17, 2010. The discovery cutoff shall be extended from January 29, 2010 to April 30, 2010. The deadline to hear dispositive motions shall be extended from March 15, 2010 to The parties respectfully request that the Court grant their request. In accordance with general Order No. 45, Section X, the filer of this document hereby attests that concurrence in the filing of this document has been obtained from each of the signatories listed below. DATED: December 23, 2009. GILBERT R. SEROTA CLARA J. SHIN MICHAEL L. GALLO HOWARD RICE NEMEROVSKI CANADY FALK & RABKIN A Professional Corporation By: s/Clara J. Shin CLARA J. SHIN Attorneys for Plaintiffs THOMAS WEISEL PARTNERS LLC and THOMAS WEISEL INTERNATIONAL PRIVATE LIMITED STEVEN T. COTTREAU CATHERINE RYLYK CLIFFORD CHANCE US LLP By: s/Steven T. Cottreau STEVEN T. COTTREAU Attorneys for Defendants BNP PARIBAS and BNP PARIBAS SECURITIES (ASIA) LIMITED STIPULATED REQUEST FOR ORDER EXTENDING DISCOVERY DEADLINES C-07-6198 MHP -2- 1 2 3 4 5 Attorneys for Defendant PRAVEEN CHAKRAVARTY By: s/Johanna Calabria JOHANNA CALABRIA RAGESH K. TANGRI JOHANNA CALABRIA DURIE TANGRI LLP 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATED REQUEST FOR ORDER EXTENDING DISCOVERY DEADLINES C-07-6198 MHP ORDER Pursuant to stipulation, the foregoing is approved and IT IS SO ORDERED. January 4, 2010 DATED: December ___, 2009 THE HONORABLE MARILYN HALL PATEL UNITED STATES DISTRICT JUDGE ERED UNIT ED S S DISTRICT TE C TA RT U O ER N F D IS T IC T O R -3- A C LI FO arily Judge M n H. Pa tel R NIA IT IS S O ORD NO RT H

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