eForce Global, Inc. v. Bank of America Corporation

Filing 28

STIPULATION AND ORDER Extending Discovery Deadlines.. Signed by Judge Samuel Conti on 4/20/10. (tdm, COURT STAFF) (Filed on 4/20/2010)

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A limited liability partnership formed in the State of Delaware

David C. Powell (SBN 129781) Email: [e-mail] William R. Overend (SBN 180209) Email: [e-mail] David S. Reidy (SBN 225904) Email: [e-mail] REED SMITH LLP 101 Second Street, Suite 1800 San Francisco, CA 94105-3659 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants, Bank of America, N.A., sued erroneously as Bank of America Corporation UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA EFORCE GLOBAL, INC., Plaintiff, vs. BANK OF AMERICA CORPORATION, et al, and Does 1 - 100, Defendants. Civil Action No. CV-091984-SC STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY DEADLINES

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REED SMITH LLP

Hon. Samuel Conti

Plaintiff eForce Global, Inc. ("eForce") and defendant Bank of America, N.A. ("Bank of America"), by and through their respective attorneys, stipulate and agree as follows: 1. This Court has set the discovery cutoff date for this case as May 26, 2010, pursuant to

its Status Conference Order, dated August 28, 2009. 2. Both eForce and Bank of America (collectively, the "Parties") have diligently

participated in discovery and mediation efforts in this action. 3. The parties participated in mediation in November, 2009, but were unsuccessful in

reaching a resolution to the case. Subsequently, eForce obtained new counsel, and the parties have been working to schedule and conduct over 15 depositions, many of them involving out-of-state witnesses. One witness who resides in Hong Kong and must travel to the United States for his deposition has limited availability.

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STIPULATION AND PROPOSED ORDER TO EXTEND DISCOVERY DEADLINES

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A limited liability partnership formed in the State of Delaware

4.

The Parties do not seek a delay of the trial date, and agree that these modifications to

the dates will serve efficiency and allow the completion of fact and expert discovery. This is the first request to modify the pretrial schedule. THEREFORE, IT IS HEREBY STIPULATED that: The deadline to complete lay discovery in this action be extended from May 26, 2010, to June 25, 2010. The deadline for hearings on dispositive motions in this action be extended from June 11, 2010, to June 25, 2010. The deadline for both parties' opening expert disclosures and reports in this action be extended from April 26, 2010, to May 21, 2010. The deadline for both parties' rebuttal expert disclosures and reports in this action be extended from April 26, 2010 to June 18, 2010. The deadline for completing expert discovery in this action be extended to June 30, 2010. DATED: April 19, 2010 MARTIN H. KRESSE, ESQ. By /s/ Martin H. Kresse Martin H. Kresse Attorneys for Plaintiffs eForce Global, Inc.

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REED SMITH LLP

DATED: April 19, 2010

REED SMITH LLP

By

/s/ David S. Reidy David S. Reidy Attorneys for Defendant Bank of America, N.A.
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PURSUANT TO STIPULATION, IT IS SO ORDERED.

Hon. SAMUEL CONTI ER C United States District Court N D IS T RIC T O F Judge
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STIPULATION AND PROPOSED ORDER TO EXTEND DISCOVERY DEADLINES

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April 20, 2010 DATED: ______________________

Judge S

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