Interwoven, Inc. v. Vertical Computer Systems, Inc.

Filing 97

STIPULATION AND ORDER RE 96 FOR CONSOLIDATION OF THE CASE MANAGEMENT CONFERENCE WITH THE MOTION TO STAY HEARING. Case Management Conference set for 3/1/2012 01:30 PM in Courtroom 3, 17th Floor, San Francisco.Signed by Judge Richard Seeborg on 2/13/12. (cl, COURT STAFF) (Filed on 2/13/2012)

*E-Filed 2/13/12*
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ATTORNEYS AT LAW

W HITE & C ASE LLP

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NOAH A. BRUMFIELD (Cal. Bar No. 203653)
[e-mail]
BIJAL V. VAKIL (Cal. Bar No. 192878)
[e-mail]
JENNIFER P. GOSSAIN (Cal. Bar No. 254174)
[e-mail]
THOMAS C. FLYNN (Cal. Bar. No. 257945)
[e-mail]
WHITE & CASE LLP
5 Palo Alto Square, 9th Floor
3000 El Camino Real
Palo Alto, CA 94306
Telephone: [phone]
Facsimile: [phone]
ATTORNEYS FOR PLAINTIFF AND COUNTERCLAIMDEFENDANT INTERWOVEN, INC.
Mark V. Isola (Cal. Bar No. 154614)
[e-mail]
REHON & ROBERTS, APC
830 The Alameda
San Jose, CA 95126
Phone: [phone]
Fax: [phone]
Vasilios D. Dossas (Pro Hac Vice)
[e-mail]
NIRO, HALLER & NIRO
181 West Madison, Suite 4600
Chicago, IL 60602-4515
Phone: [phone]
Fax: [phone]
ATTORNEYS FOR DEFENDANT AND COUNTERCLAIMANT
VERTICAL COMPUTER SYSTEMS, INC.

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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Plaintiff,

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INTERWOVEN, INC.,

vs.
VERTICAL COMPUTER SYSTEMS, INC.,

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Defendant.

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PALOALTO 114990 (2K)

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CIVIL CASE NO.: 3:10-cv-04645-RS
STIPULATED REQUEST FOR
CONSOLIDATION OF THE CASE
MANAGEMENT CONFERENCE WITH THE
HEARING FOR THE MOTION TO STAY AND
[PROPOSED] ORDER
JURY TRIAL DEMANDED

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Pursuant to Civil Local Rules 6-2 and 7-12 of the Northern District of California,

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Plaintiff and Counterclaim-Defendant Interwoven, Inc. (“Interwoven”) and Defendant and

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Counterclaimant Vertical Computer Systems, Inc. (“Vertical”), by and through their respective

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counsel of record, jointly request for an Order Continuing the Case Management Conference

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currently scheduled for February 23, 2012 at 10 a.m. to March 1, 2012 at 10 a.m., and a

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corresponding extension of time from February 16, 2012 to February 23, 2012 to file the

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supplemental joint case management statement.

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The parties request this short continuance in order to accommodate pre-existing travel

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plans of lead counsel for Interwoven, Bijal V. Vakil, and to consolidate the case management

ATTORNEYS AT LAW

conference with the hearing on Interwoven’s Motion to Stay, scheduled for March 1, 2012. See

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W HITE & C ASE LLP

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Dkt No. 86.

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The Court’s current scheduling order has no deadlines beyond the case management

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conference, and thus no additional deadlines will be affected by this request. See Dkt. 58. The

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parties respectfully request that the Court not construe this request as a waiver to any position

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taken with respect to the pending motion for a stay. The Declaration of Bijal V. Vakil, filed

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concurrently with this request, provides the information required by Civil L.R. 6-2(a)(1)-(3).

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The parties’ stipulated request herein is not made for purposes of delay or harassment,

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but is based in good faith upon the grounds stated above. For these reasons, the parties

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respectfully request an Order from this Court continuing the date for the Case Management

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Conference from February 23, 2012 at 10 a.m. to March 1, 2012 at 10 a.m. 1:30 p.m.

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PALOALTO 114990 (2K)

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STIPULATED REQUEST FOR CONSOLIDATION OF CMC WITH
HEARING ON MOTION TO STAY
CASE NO.: 3:10-CV-04645-RS

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Dated: February 10, 2012

Respectfully submitted,

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WHITE & CASE LLP

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By:

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ATTORNEYS FOR PLAINTIFF AND COUNTERCLAIMDEFENDANT INTERWOVEN, INC.

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Dated: February 10, 2012

Respectfully submitted,

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NIRO, HALLER & NIRO

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By:

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ATTORNEYS AT LAW

/s/ Vasilios D. Dossas
VASILIOS D. DOSSAS
ATTORNEYS FOR DEFENDANT AND
COUNTERCLAIMANT VERTICAL COMPUTER
SYSTEMS, INC.

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W HITE & C ASE LLP

/s/ Bijal V. Vakil
BIJAL V. VAKIL

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The Court finds that the Stipulated Request for an Order Consolidating the Case

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Management Conference with the Hearing on the Motion to Stay is well taken and should be

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GRANTED.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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2/13/12
Dated: ________________________

_____________________________
Honorable Richard Seeborg
United States District Court Judge

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PALOALTO 114990 (2K)

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STIPULATED REQUEST FOR CONSOLIDATION OF CMC WITH
HEARING ON MOTION TO STAY
CASE NO.: 3:10-CV-04645-RS