E-Pass Technologies, Inc. v. Moses & Singer, LLP et al

Filing 192

STIPULATION AND ORDER re 191 AN EXTENSION OF TIME TO FILE A JOINT CMC STATEMENT AND PARTIES UPDATED OFFERS OF PROOF filed by E-Pass Technologies, Inc. Status Report due by 9/25/2012.. Signed by Judge Edward M. Chen on 9/20/12. (bpf, COURT STAFF) (Filed on 9/20/2012)

1
2
3
4
5
6
7

JAMES R. ROSEN, ESQ. (State Bar No. 119438)
[e-mail]
RYAN D. SABA, ESQ. (State Bar No. 192370)
[e-mail]
LAURA L. CABLE, ESQ. (State Bar No. 278432)
[e-mail]

Members of Rosen ✧ Saba, llp
468 North Camden Drive, Third Floor
Beverly Hills, California 90210
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff,
E-PASS TECHNOLOGIES, INC.

8
9

UNITED STATES DISTRICT COURT

ROSEN SABA, LLP
468 NORTH CAMDEN DRIVE, 3RD FLOOR
BEVERLY HILLS, CALIFORNIA 90210

10

FOR THE NORTHERN DISTRICT OF CALIFORNIA

11

SAN FRANCISCO DIVISION

12
13

E-PASS TECHNOLOGIES, INC., a
Delaware Corporation,

14
15
16
17
18
19
20

Plaintiff,
vs.
MOSES & SINGER, LLP, a New
York Limited Partnership;
STEPHEN N. WEISS, ESQ., an
Individual; and DOES 1 through 50,
inclusive,
Defendants.

Case No. 3:09-cv-05967-EMC
Honorable Edward M. Chen
STIPULATION BY AND BETWEEN
PLAINTIFF AND DEFENDANTS
REGARDING AN EXTENSION OF
TIME TO FILE A JOINT CMC
STATEMENT AND PARTIES’
UPDATED OFFERS OF PROOF;
[Proposed] ORDER

Complaint Filed: December 21, 2009
Trial Date:
February 4, 2013

21
22
23
24
25
26
27
28

STIPULATION BY AND BETWEEN PLAINTIFF AND DEFENDANTS
REGARDING AN EXTENSION OF TIME FOR FILING

1
2
3
4
5
6
7
8
9

ROSEN SABA, LLP
468 NORTH CAMDEN DRIVE, 3RD FLOOR
BEVERLY HILLS, CALIFORNIA 90210

10
11
12
13
14
15
16

TO THIS HONORABLE COURT AND ALL PARTIES AND THEIR
COUNSEL OF RECORD HEREIN:
(1)

WHEREAS, on August 1, 2012, the Court issued an Order re Parties’

Second Offers of Proof as to Phase One of Trial. [USDC Docket #179.] Part of
this Order directed the parties to file an updated joint CMC statement with their
updated offers of proof as to Phase One of the trial no later than September 21,
2012 in preparation for a status conference on October 5, 2012, at 10:30 a.m.
(2) WHEREAS, the parties met and conferred regarding the joint CMC
statement and agreed that all parties would benefit from a slight extension of time
with the Court’s approval.
Now, therefore, the parties, by and through their counsel of record,
STIPULATE as follows:
(A)

The parties respectfully request the Court to permit the parties to file

the joint CMC statement and the parties’ updated offers of proof as to Phase One of
the trial no later than September 25, 2012.

17
18

IT IS SO STIPULATED.

19
20

Dated: September 19, 2012

ROSEN

SABA, LLP

21
22

By: /s

________________________
JAMES R. ROSEN, ESQ.
RYAN D. SABA, ESQ.
LAURA L. CABLE
Attorneys for Plaintiff,
E-PASS TECHNOLOGIES, INC.

23
24
25
26
27
28

1

STIPULATION BY AND BETWEEN PLAINTIFF AND DEFENDANTS
REGARDING AN EXTENSION OF TIME FOR FILING

1
2

Dated: September 19, 2012

DUANE MORRIS, LLP

3
4

By:/s

________________________
RICHARD D. HOFFMAN, ESQ.
ROBERT M. FINEMAN, ESQ.
Attorneys for Defendant,
MOSES & SINGER, LLP

5
6
7
8
9

Dated: September 19, 2012

LONG & LEVIT, LLP

ROSEN SABA, LLP
468 NORTH CAMDEN DRIVE, 3RD FLOOR
BEVERLY HILLS, CALIFORNIA 90210

10
11

By: /s

________________________
JOSEPH MCMONIGLE, ESQ.
JESSICA R. MACGREGOR, ESQ.
Attorneys for Defendant,
STEPHEN N. WEISS

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

2

STIPULATION BY AND BETWEEN PLAINTIFF AND DEFENDANTS
REGARDING AN EXTENSION OF TIME FOR FILING

1
2
3
4
5
6
7
8
9

[Proposed] ORDER
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD
HEREIN:
The Court received and reviewed the Stipulation by and between Plaintiff
and Defendants regarding Expert Reports and Discovery [USDC Docket # __.]
After consideration of the Stipulation, and good cause appearing, the Court
orders as follows:
(A)

The joint CMC statement with the parties’ updated offers of proof as

to Phase One of the trial will be filed no later than September 25, 2012.

11

16

RT

17

19

hen

rd M. C

dwa
Judge E

ER

H

18

R NIA

15

D

RDERE
_______________________
IS SO O
IT
Honorable Edward M. Chen
FO

By:

LI

9/20/12
Date: ________________

A

14

UNIT
ED

13

S DISTRICT
TE
C
TA

RT
U
O

IT IS SO ORDERED.
S

12

NO

ROSEN SABA, LLP
468 NORTH CAMDEN DRIVE, 3RD FLOOR
BEVERLY HILLS, CALIFORNIA 90210

10

N

F
D IS T IC T O
R

C

20
21
22
23
24
25
26
27
28

3

STIPULATION BY AND BETWEEN PLAINTIFF AND DEFENDANTS
REGARDING AN EXTENSION OF TIME FOR FILING