U2 Home Entertainment, Inc. v. Hanya Star Culture & Technology Co., Ltd. et al
Filing
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ORDER GRANTING 66 Stipulation for Order to Extend Time to Submit Supplemental CMC Statement (including Proposed Trial Schedule). Signed by Judge JEFFREY S. WHITE on 8/1/11. (jjoS, COURT STAFF) (Filed on 8/1/2011)
Case3:10-cv-05615-JSW Document66
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Filed07/29/11 Page1 of 5
RICHARD J. IDELL (SBN: 069033)
ELIZABETH J. REST (SBN: 244756)
IDELL & SEITEL LLP
465 California Street, Suite 300
San Francisco, CA 94104
Telephone: (415) 986-2400
Facsimile: (415) 392-9259
Emails: richard.idell@idellseitel.com; erest@idellseitel.com
Attorneys for Plaintiff U2 HOME ENTERTAINMENT, INC.
TOD L. GAMLEN (SBN: 83458)
KEITH L. WURSTER (SBN: 198918)
BAKER & McKENZIE LLP
660 Hansen Way
Palo Alto, CA 94304-1044
Telephone: (650) 856-2400
Facsimile: (650) 856-9299
Emails: tod.gamlen@bakermckenzie.com; keith.wurster@bakermckenzie.com
Attorneys for Defendant
iTALK GLOBAL COMMUNICATIONS, INC. dba iTALKBB
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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NORTHERN DIVISION
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)
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Plaintiff,
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vs.
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HANYA STAR CULTURE & TECHNOLOGY
CO., LTD., a foreign corporation doing business in )
California, and doing business as HANYA STAR )
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COMPANY, INC.; ITALK GLOBAL
COMMUNICATIONS, INC., a foreign corporation )
doing business in California, and doing business as )
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ITALKBB; and DOES 1 through 100, inclusive,
)
)
Defendants.
U2 HOME ENTERTAINMENT, INC., a California
Corporation doing business as CENTURY HOME
ENTERTAINMENT and TAI SENG
ENTERTAINMENT,
Case No.: CV 10-05615 JSW
STIPULATION FOR ORDER TO
EXTEND TIME TO SUBMIT
SUPPLEMENTAL CMC STATEMENT
(INCLUDING PROPOSED TRIAL
SCHEDULE); ORDER [PROPOSED]
THEREON
Complaint Filed: December 10, 2010
First Amended Complaint Filed: March 11,
2011
Honorable Judge Jeffrey S. White, Presiding
(E-filing)
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STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO SUBMIT PROPOSED TRIAL SCHEDULE
Case No.: CV 10-05615 JSW
Case3:10-cv-05615-JSW Document66
Filed07/29/11 Page2 of 5
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Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure and Rule 6-1(b) of the Civil Local
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Rules of the United States District Court, Northern District of California, Plaintiff U2 HOME
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ENTERTAINMENT, INC., a California corporation, doing business as CENTURY HOME
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ENTERTAINMENT and TAI SENG ENTERTAINMENT (“U2” or “Plaintiff”), on the one hand, and
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Defendant iTALK GLOBAL COMMUNICATIONS, INC., doing business as iTALKBB (“Defendant”
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or “iTalk”), on the other hand, hereby agree and stipulate as follows:
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WHEREAS, a Case Management Conference was held in this matter on July 22, 2011, at 1:30
p.m. in Courtroom 11; and
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WHEREAS, at the Case Management Conference the Honorable Judge Jeffrey S. White ordered
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counsel for U2 and Defendant iTalk to submit a supplemental CMC Statement (“Supplemental CMC
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Statement”)setting forth a schedule for the pre-trial proceedings (to cover up to the hearing date for
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dispositive motions) by no later than July 29, 2011; and
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WHEREAS, all of the parties to this case, including Defendant HANYA STAR CULTURE &
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TECHNOLOGY CO., LTD., a foreign corporation doing business in California, and doing business as
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HANYA STAR COMPANY, INC., who has not yet been served, have been engaging in settlement
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discussions and are very close to reaching a settlement of this matter;
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WHEREAS, one or more parties have asked their counsel not to engage in additional work
pending the outcome of such settlement discussions; and
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WHEREAS, in light of these events the parties believe it would serve judicial economy and
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conserve resources if the time to submit the Supplemental CMC Statement be extended by thirty (30)
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so that the parties can hopefully complete a settlement of this matter without incurring additional
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attorneys’ fees; and
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WHEREAS, Rule 6-1(b) of the Civil Local Rules of the United States District Court, Northern
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District of California, permits the parties to request an enlargement of time by stipulation in writing;
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and
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WHEREAS, Plaintiff and Defendant iTalk agree that the requested enlargement of time will
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allow the parties adequate time to further discuss settlement and potentially reach a settlement of this
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matter; and
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STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO SUBMIT PROPOSED TRIAL SCHEDULE
Case No.: CV 10-05615 JSW
Case3:10-cv-05615-JSW Document66
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Filed07/29/11 Page3 of 5
WHEREAS, Plaintiff and Defendant iTalk agree that the date by which Plaintiff and iTalk shall
submit the Supplemental CMC Statement shall be no later than August 29, 2011, and;
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NOW THEREFORE, Plaintiff and Defendant iTalk, by and through their respective
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undersigned counsel, hereby stipulate that the time for the Plaintiff and Defendant iTalk to submit the
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Supplemental CMC Statement that was ordered by the Court at the July 22, 2011 Case Management
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Conference be extended up to and including August 29, 2011; and
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SO STIPULATED.
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IDELL & SEITEL LLP
Dated: July 29, 2011
By:
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Dated: July 29, 2011
/Richard J. Idell/
Richard J. Idell
Attorneys for Plaintiff U2 HOME ENTERTAINMENT,
INC.
BAKER & McKENZIE LLP
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By:
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/Tod L. Gamlen/
Tod L. Gamlen
Attorneys for Defendant
iTALK GLOBAL COMMUNICATIONS, INC. dba iTALK
BB
ATTESTATION OF CONCURRENCE
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I, Richard J. Idell, attest that I am one of the attorneys for Plaintiff U2 Home Entertainment,
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Inc., and as the ECF user and filer of this document, I attest that, pursuant to General Order No.
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45(X)(B), concurrence in the filing of this document has been obtained from Tod L. Gamlen, the above
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signatory.
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Dated: July 29, 2011
By:
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/Richard J. Idell/
Richard J. Idell
[PROPOSED] ORDER
IT IS SO ORDERED.
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STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO SUBMIT PROPOSED TRIAL SCHEDULE
Case No.: CV 10-05615 JSW
Case3:10-cv-05615-JSW Document66
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Filed07/29/11 Page4 of 5
Dated: August 1, 2011
Hon. Jeffrey S. White
Judge of the United States District Court
Northern District of California
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STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO SUBMIT PROPOSED TRIAL SCHEDULE
Case No.: CV 10-05615 JSW
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