Iguacu, Inc. v. Filho

Filing 115

STIPULATION AND ORDER RE 114 TO CONTINUE CASE MANAGEMENT CONFERENCE. Further Case Management Conference set for 4/7/2011 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Signed by Judge Richard Seeborg on 12/22/10. (cl, COURT STAFF) (Filed on 12/22/2010)

Iguacu, Inc. v. Filho

Doc. 115

*E-Filed 12/22/10*
1 2 3 4 5 6 7 8 9 10 11 Plaintiff, 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiff Iguaçu, Inc. ( Iguaçu ) and Defendant Antonio Cabrera Mano Filho ( Mr. Cabrera ) jointly request that the Further Case Management Conference currently set for Thursday, January 13, 2011, be continued to April 7, 2011, for the following reasons: 1. On October 7, 2010, the Court issued a Case Management Scheduling Order referring v. ANTONIO CABRERA MANO FILHO, Defendant. STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE FROM JANUARY 13, 2011 TO APRIL 7, 2011 IGUAÇU, INC., UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA Case No. C 09-0380 RS (EMC) EDWARD P. SANGSTER (State Bar No.121041) [e-mail] CLAUDIA A. QUIROZ (State Bar No. 254419) [e-mail] K&L GATES LLP 4 Embarcadero Center, Suite 1200 San Francisco, CA 94111 Telephone: [phone] Facsimile: 415.882.8220 Attorneys for Defendant ANTONIO CABRERA MANO FILHO

the case to a Magistrate Judge for a Settlement Conference. The Court ordered that the settlement conference had to be completed no later than ninety days from the entry of the Court s order. [Dkt. No. 95.] The Court also set a Further Case Management Conference for January 13, 2011. 2. On December 13, 2010, the parties filed an Amended Joint Application to Continue

the Settlement Conference, which was scheduled for December 23, 2010. [Dkt. No. 109]. On December 14, 2010, the Court extended the time for the parties to complete the settlement conference to April 1, 2011 pursuant to the parties stipulated request. [Dkt. No. 110]. On December 15, 2010, Honorable Magistrate Judge Bernard Zimmerman continued the Settlement Conference from 1 STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE; CASE NO. CV 09-0380 RS (EMC)
Dockets.Justia.com

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December 23, 2010 to March 17, 2011 pursuant to the Joint Application of the parties. [Dkt. No. 113]. 3. Iguaçu is currently not in a position to analyze the value of its claims for settlement

purposes, and does not expect to be able to do so until mid-February 2011 at the earliest. Additionally, the parties will be in a better position to determine their respective subsequent steps in this litigation following the March 17, 2011 settlement conference. 4. Accordingly, because the Further Case Management Conference is much more likely

to be productive following the Settlement Conference, the parties respectfully request that the Further Case Management Conference currently scheduled for January 13, 2011 be continued to April 7, 2011 at 10:00 a.m. IT IS SO STIPULATED.

K&L GATES LLP

Dated: December 22, 2010

By:

/s/ Claudia A. Quiroz Edward P. Sangster [e-mail] Claudia A. Quiroz [e-mail] Attorneys for Defendant ANTONIO CABRERA MANO FILHO SIDEMAN & BANCROFT, LLP

Dated: December 22, 2010

By: /s/ Robert R. Cross Robert R. Cross [e-mail] Attorney for Plaintiff IGUACU, INC.

2 STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE; CASE NO. CV 09-0380 RS (EMC)

1 2 3 4 5 6 7 8 9 10 11 12 13 Dated: December 22, 2010

ECF ATTESTATION I, Claudia A. Quiroz, attest that concurrence in e-filing this STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE FROM JANUARY 13, 2011 TO APRIL 7, 2011, has been obtained from signatory Robert R. Cross, in compliance with General Order 45, X.B. K&L GATES LLP

By:

/s/ Claudia A. Quiroz Edward P. Sangster [e-mail] Claudia A. Quiroz [e-mail] Attorneys for Defendant ANTONIO CABRERA MANO FILHO

[PROPOSED] ORDER 14 Pursuant to the Stipulation of counsel and for good cause shown, IT IS HEREBY 15 16 17 prior to the Conference 18 IT IS SO ORDERED. 19 20 21 22 23 24 25 26 27 28 3 STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE; CASE NO. CV 09-0380 RS (EMC) ORDERED that the Case Management Conference currently set for January 13, 2011 is continued to at 10:00 a.m. April 7, 2011. The parties shall submit their Joint Case Management Statement at least one week

22 Dated: December ___, 2010

By: Honorable Richard Seeborg UNITED STATES DISTRICT JUDGE