Sonoma Tires, Inc. v. Big O Tires, LLC

Filing 39

STIPULATION AND ORDER RE 38 LITIGATION DEADLINES. Signed by Judge Richard Seeborg on 7/13/12. (cl, COURT STAFF) (Filed on 7/13/2012)

1
2
3
4
5
6
7
8
9
10
11
12
13

SEYFARTH SHAW LLP
Michael J. Burns (SBN 172614)
E-mail: [e-mail]
Michael T. McKeeman (SBN 173662)
E-mail: [e-mail]
Joseph J. Orzano (SBN 262040)
E-mail: [e-mail]
560 Mission Street, Suite 3100
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
Attorneys for Big O Tires, LLC
LAGARIAS & BOULTER LLP
Peter C. Lagarias (SBN 77091)
E-mail: [e-mail]
Robert S. Boulter (SBN 153549)
E-mail: [e-mail]
1629 Fifth Avenue
San Rafael, California 94901-1828
Telephone: [phone]
Facsimile: [phone]
Attorneys for Sonoma Tires, Inc. and
John G. Rhiel, IV

14

UNITED STATES DISTRICT COURT

15

NORTHERN DISTRICT OF CALIFORNIA

16
17

SAN FRANCISCO DIVISION

18

SONOMA TIRES, INC., a California
Corporation,

19

Plaintiff,

20
21

v.
BIG O TIRES, LLC, a Colorado Limited
Liability Company,

22

Defendant.

23
24
25

)
)
)
)
)
)
)
)
)
)
)
)
)
)

Case No. C 11-0818 RS
STIPULATION REGARDING
LITIGATION DEADLINES AND
[PROPOSED] ORDER
[L.R. 7-12]

Big O Tires, LLC (“Big O”), on the one hand, and Sonoma Tires, Inc. (“Sonoma”) and

26

John G. Rhiel, IV (“Rhiel”), on the other hand, (collectively, “Parties”) by and through their

27

respective undersigned counsel, hereby stipulate and jointly request that the Court issue an Order

28

as follows:
1
Stipulation Regarding Litigation Deadlines and [Proposed] Order;
Case No. C11-0818RS

1
2

WHEREAS, the parties current deadline to complete non-expert depositions is July 16,
2012;

3
4

WHEREAS, the parties have completed some but not all non-expert depositions in this
matter;

5
6

WHEREAS, the parties have met and conferred and, due to scheduling issues, desire to
complete all discovery, including depositions, by on or before August 3, 2012;

7
8

WHEREAS, the current scheduling order, as modified by the Court’s May 4, 2012 Order,
provides adequate time to allow for the requested modification without extending the trial date;

9

IT IS THEREFORE STIPULATED AND JOINTLY REQUESTED that:

10

1.

11

The Court order that the parties shall have up to and including August 3, 2012 to
complete non-expert discovery, including non-expert depositions;

12

2.

The Court order that the parties shall have up to and including October 11, 2012

13

to have heard all pretrial motions, including but not limited to any motion for

14

summary judgment and/or summary adjudication; and

15

3.

All other deadlines remain as set forth the Court’s scheduling order.

16

IT IS SO STIPULATED.

17
18

SEYFARTH SHAW LLP

19

By /s/ Joseph J. Orzano_________
Joseph J. Orzano
Attorneys for Big O Tires, LLC

20

LAGARIAS & BOULTER, LLP

21

Dated: July 13, 2012

Dated: July 13, 2012

22
23

///

24

///

25

By /s/ Peter C. Lagarias_ _________
Peter C. Lagarias
Attorneys for Sonoma Tires, Inc. and
John G. Rhiel, IV

///

26
27
28
2
Stipulation Regarding Litigation Deadlines and [Proposed] Order;
Case No. C11-0818RS

1

[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED,

2
3

1.

The parties shall have up to and including August 3, 2012 to complete non-expert
discovery, including non-expert depositions;

4
5

2

All pretrial motions shall be heard no later than October 11, 2012; and

6

3.

All other deadlines remain as set forth in the Court’s scheduling order.

7
8

7/13/12
Dated: __________________

________________________
The Honorable Richard Seeborg

9
14665475v.1

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
3
Stipulation Regarding Litigation Deadlines and [Proposed] Order;
Case No. C11-0818RS