Perdana Capital (Labuan) Inc. v. Chowdry et al

Filing 145

STIPULATION AND ORDER RE 143 THE DISCLOSURE AND DISCOVERY OF EXPERT WITNESS OPINIONS. Signed by Judge Richard Seeborg on 10/25/11. (cl, COURT STAFF) (Filed on 10/26/2011)

*E-Filed 10/26/11*

1

5

Michael Q. Eagan (CA #63479)
Thomas H. Manulkin (CA #229630)
LAW OFFICES OF MICHAEL Q. EAGAN
Three Embarcadero Center
Eighth Floor
San Francisco, California 94111
Telephone: [phone]
Fax:
[phone]
E-mail:
[e-mail]

6

Attorneys for Defendants

2
3
4

7
8

UNITED STATES DISTRICT COURT FOR THE

9

NORTHERN DISTRICT OF CALIFORNIA

10
11
12
13
14
15
16
17
18
19
20
21

)
)
)
)
Plaintiff,
)
)
v.
)
)
MOHAMMAD AKRAM CHOWDRY, an
Individual; HI-TECH VENTURE PARTNERS, )
LLC, a Delaware Limited Liability Company; )
)
HI-TECH ASSOCIATES, LLC, a California
Limited Liability Company; and DOES 1-50, )
)
)
Defendants.
)
)
)
)
)
)
)
______________________________________ )
PERDANA CAPITAL (LABUAN) INC., a
Malaysian Corporation,

CASE NO. CV 09-01479 RS
Assigned to Hon. Richard Seeborg
STIPULATION AND [PROPOSED]
ORDER REGARDING THE
DISCLOSURE AND DISCOVERY OF
EXPERT WITNESS OPINIONS

22
23
24
25
26
27
28

-1CASE NO. CV 09-01479 RS
STIPULATION AND [PROPOSED] ORDER REGARDING THE DISCLOSURE AND DISCOVERY OF
EXPERT WITNESS OPINIONS

1

IT IS HEREBY AGREED AND STIPULATED by the parties hereto, by and through

2

their respective attorneys that are authorized to enter into this stipulation, that section 3, titled

3

“EXPERT WITNESSES,” of the Case Management Scheduling Order dated March 7, 2011 shall

4

be amended as follows for the following reasons:

5
6

WHEREAS, on June 28, 2011, the parties filed a joint letter with Magistrate Judge Spero
raising a number of issues related to discovery in this case;

7

WHEREAS, on July 25, 2011 Magistrate Judge Cousins signed the parties’ Stipulation

8

and Order Regarding Discovery Disputes (“Order”) to resolve the issues raised in the June 28,

9

2011 letter to Judge Spero;

10
11

WHEREAS, since the entry of the Order, the parties have been attempting to complete
the discovery required under the Order;

12
13

WHEREAS, due to the delay in completing discovery the experts do not have all of the
information they need to draft their respective expert opinions;

14

NOW, THEREFORE, IT IS HEREBY STIPULATED, AGREED AND

15

RESPECTFULLY REQUESTED by the undersigned Parties, that section 3, titled “EXPERT

16

WITNESSES,” of the Case Management Scheduling Order dated March 7, 2011 shall be

17

amended as follows:

18
19

3.
as follows:

20
21

A.

On or before January 10, 2012, plaintiff shall disclose expert testimony and

reports in accordance with Federal Rule of Civil Procedure 26(a)(2).

22
23

EXPERT WITNESSES, The disclosure of expert witness opinions shall proceed

B.

On or before February 7, 2012, defendants shall disclose expert testimony and

reports in accordance with Federal Rule of Civil Procedure 26(a)(2).

24

C.

On or before March 20, 2012, all discovery of expert witnesses pursuant to

25

Federal Rule of Civil Procedure 26(b)(4) shall be completed.

26

//

27

//

28

-2CASE NO. CV 09-01479 RS
STIPULATION AND [PROPOSED] ORDER REGARDING THE DISCLOSURE AND DISCOVERY OF
EXPERT WITNESS OPINIONS

1
2

IT IS SO STIPULATED AND RESPECTFULLY REQUESTED.
Dated: October 25, 2011

3

Respectfully submitted,

4

LAW OFFICES OF MICHAEL Q. EAGAN

5
By:______________/s/__________________
THOMAS H. MANULKIN

6
7

Attorneys for defendants Mohammad
Akram Chowdry, Hi-Tech Venture Partners,
LLC and Hi-Tech Associates, LLC

8
9

Dated: October 25, 2011

10

Respectfully submitted,

11

KAUFMAN DOLOWICH VOLUCK & GONZO

12
By:______________/s/__________________
JOSEPH KOURI
JOSEPH J. DE HOPE, JR.

13
14

Attorneys for plaintiff Perdana Capital
(Labaun), Inc.

15
16
17

I, Thomas H. Manulkin, of the Law Offices of Michael Q. Eagan, whose ID and

18

password are being used to file this Stipulation and [Proposed] Order, hereby, attest, in

19

accordance with General Order 45 X(B), that Joseph J. De Hope, Jr. of Kaufman Dolowich

20

Voluck and Gonzo, LLP has concurred in this filing.

21

Dated: October 25, 2011

22

Respectfully submitted,

23

LAW OFFICES OF MICHAEL Q. EAGAN

24
25

By:______________/s/__________________
THOMAS H. MANULKIN

26

Attorneys for defendants Mohammad
Akram Chowdry, Hi-Tech Venture Partners,
LLC and Hi-Tech Associates, LLC

27
28

-3CASE NO. CV 09-01479 RS
STIPULATION AND [PROPOSED] ORDER REGARDING THE DISCLOSURE AND DISCOVERY OF
EXPERT WITNESS OPINIONS

1
2

PURSUANT TO STIPULATION, IT IS SO ORDERED
10/25
Dated: ________________, 2011

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

3
4
5

____________________________________
THE HON. RICHARD SEEBORG
UNITED STATES DISTRICT JUDGE

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

-4CASE NO. CV 09-01479 RS
STIPULATION AND [PROPOSED] ORDER REGARDING THE DISCLOSURE AND DISCOVERY OF
EXPERT WITNESS OPINIONS