Techsavies, LLC v. WDFA Marketing, Inc.

Filing 31

ORDER Signed by Magistrate Judge Bernard Zimmerman granting re 30 Motion to Amend Scheduling Order. (bzsec, COURT STAFF) (Filed on 10/29/2010)

Techsavies, LLC v. WDFA Marketing, Inc.

Doc. 31

1 James C. Pistorino (SBN 226496) Daniel T. Shvodian (SBN 184576) 2 Richard C. Lin (SBN 209233) HOWREY LLP 3 1950 University Avenue, 4th Floor East Palo Alto, CA 94303 4 Telephone: [phone] Facsimile: [phone] 5 Email: [e-mail] Email: [e-mail] 6 Email: [e-mail] 7 Attorneys for Plaintiff TECHSAVIES, LLC 8 9 10 11 12 13 TECHSAVIES, LLC, 14 15 v. Plaintiff, Case No. CV-10-1213-BZ JOINT MOTION AND [PROPOSED] ORDER TO AMEND SCHEDULING ORDER UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

16 WDFA MARKETING, INC., 17 18 19 20 21 22 23 24 25 26 27 28
Case No. CV-10-1213-BZ JOINT MOTION & [PROPOSED] ORDER TO AMEND SCHEDULING ORDER

Defendant.

Dockets.Justia.com

1

Following the conclusion of the ENE Conference on October 29, 2010, Plaintiff Techsavies,

2 LLC and Defendant WDFA Marketing, Inc., by and through their respective counsel, agreed to a 303 day extension for non-expert discovery for the purpose of addressing issues raised during the ENE, 4 which the parties believe may assist them in resolving this matter. 5 In view of the foregoing, the parties respectfully request that the Court amend the Scheduling

6 Order to extend certain deadlines as set forth below. None of the proposed changes impact any Court 7 deadlines, including the trial date. 8 9 10 11 12 13 14 15 16 17 Dated: October 22, 2010 18 19 20 21 22 23 24 25 26 27 28
Case No. 10-CV-03248-JF -1JOINT STIPULATION & [PROPOSED] ORDER TO CONTINUE NOVEMBER 5, 2010 INITIAL CASE MANAGEMENT CONFERENCE

EVENT Cutoff for non-expert discovery Opening expert reports Responsive expert reports Close of expert discovery Last day to file dispositive motions Last day for hearing of dispositive motions Pretrial conference Trial

CURRENT DEADLINE October 29, 2010 November 19, 2010 December 10, 2010 December 22, 2010 February 9, 2011 March 16, 2011 April 26, 2011 May 16, 2011

PROPOSED NEW DEADLINE December 1, 2010 December 17, 2010 January 7, 2011 January 21, 2011 No change No change No change No change

By:

/s/ Daniel T. Shvodian Daniel T. Shvodian

Daniel T. Shvodian (SBN 184576) HOWREY LLP 1950 University Avenue, 4th Floor East Palo Alto, CA 94303 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Attorney for Plaintiff TECHSAVIES, LLC

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
Case No. CV-10-1213-BZ JOINT MOTION & [PROPOSED] ORDER TO AMEND SCHEDULING ORDER

By:

/s/ J. Daniel Sharp J. Daniel Sharp

J. Daniel Sharp (SBN 131042) CROWELL & MORING LLP 275 Battery Street, 23rd Floor San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Attorney for Defendant WDFA MARKETING, INC.

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1 2 3 4 5 6 7 8 9 Dated: 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 October 29, 2010

ORDER The parties having so stipulated, and good cause appearing, IT IS SO ORDERED that the Scheduling Order be modified as follows: EVENT Cutoff for non-expert discovery Opening expert reports Responsive expert reports Close of expert discovery NEW DEADLINE December 1, 2010 December 17, 2010 January 7, 2011 January 21, 2011

__________________________________________ Honorable Bernard Zimmerman United States Magistrate Judge

Case No. 10-CV-03248-JF -1JOINT STIPULATION & [PROPOSED] ORDER TO CONTINUE NOVEMBER 5, 2010 INITIAL CASE MANAGEMENT CONFERENCE

1 2

FILER'S ATTESTATION I, Daniel T. Shvodian, am the ECF user whose identification and password are being used to

3 file this Joint Stipulation. Pursuant to General Order No. 45, § X(B), I attest under penalty of perjury 4 that concurrence in the filing of the document has been obtained from J. Daniel Sharp. 5 6 Dated: October 22, 2010 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Case No. CV-10-1213-BZ JOINT MOTION & [PROPOSED] ORDER TO AMEND SCHEDULING ORDER

By: /s/ Daniel T. Shvodian Daniel T. Shvodian

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CERTIFICATE OF SERVICE

I am employed in the County of San Mateo, State of California. I am over the age of 18 and not a party to the within action. My business address is 1950 University Avenue, 4th Floor, East Palo 3 Alto, California 94303. 4 5 On October 22, 2010, I served the within: JOINT MOTION AND [PROPOSED] ORDER TO AMEND SCHEDULING ORDER

6 on the interested parties in said action as stated below. 7 J. Daniel Sharp Anne W. Kuykendall 8 CROWELL & MORING LLP 275 Battery Street, 23rd Floor 9 San Francisco, CA 94111 Telephone: [phone] Facsimile: 415.986.2827 Email: [e-mail] 11 Email: [e-mail] 12 Attorneys for Defendant WDFA Marketing, Inc. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
23503874

(OVERNIGHT DELIVERY) I deposited in a box or other facility regularly maintained by Federal Express, an express service carrier, or delivered to a courier or driver authorized by said express service carrier to receive documents, a true copy of the foregoing document in sealed envelopes or packages designated by the express service carrier, addressed as stated above, with fees for overnight delivery paid or provided for. (MAIL) I am readily familiar with this firm's practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the U.S. postal service on that same day in the ordinary course of business. I am aware that on motion of party served, service is presumed invalid if postal cancellation date or postage meter date is more than 1 day after date of deposit for mailing in affidavit. (PERSONAL SERVICE) I delivered such envelope(s) by hand to the offices of addressee. (BY ELECTRONIC MAIL) I caused such document(s) to be sent to the persons at the e-mail addresses listed above. I did not receive, within a reasonable time after the submission, any electronic message or other indication that the transmission was unsuccessful. X (BY CM/ECF) I caused such document(s) to be sent via electronic mail through the Case Management/Electronic File system with the U.S. District Court for the Northern District of California.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on October 22, 2010, at East Palo Alto, California. Laurie M. Hockin (Type or print name) /s/ Laurie M. Hockin (Signature)

Case No. CV-10-1213-BZ CERTIFICATE OF SERVICE