Olympic Developments AG, LLC v. Microsoft Corporation et al

Filing 105

STIPULATION AND ORDER to Continue and/or Modify Pending Case Management Deadlines. Case Management Conference set for 9/23/2011 01:30 PM in Courtroom G, 15th Floor, San Francisco. Signed by Judge Joseph C. Spero on 09/09/2011. (tmi, COURT STAFF) (Filed on 9/9/2011)

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Eric A. Buresh (admitted pro hac vice)
[e-mail]
Abran J. Kean (admitted pro hac vice)
[e-mail]
SHOOK, HARDY & BACON, L.L.P.
2555 Grand Boulevard
Kansas City, Missouri 64108
Telephone: [phone]
Andrew L. Chang (SBN: 222309)
[e-mail]
SHOOK, HARDY & BACON L.L.P.
One Montgomery, Suite 2700
San Francisco, California 94104-4505
Telephone: [phone]
Attorneys for Defendants and Counterclaimants
SONY COMPUTER ENTERTAINMENT AMERICA LLC and
SONY ELECTRONICS INC.

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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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OLYMPIC DEVELOPMENTS AG, LLC,
Plaintiff,

Case Nos. 3:11-cv-01080-JCS
consolidated with
Case No. 3:11-cv-04203-JCS

v.
JOINT STIPULATION AND
SONY COMPUTER ENTERTAINMENT
[PROPOSED] ORDER TO CONTINUE
AMERICA LLC and SONY ELECTRONICS INC., AND/OR MODIFY PENDING CASE
MANAGEMENT DEADLINES;
Defendants.
DECLARATION OF ABRAN J. KEAN
IN SUPPORT

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JOINT STIPULATION TO CONTINUE DEADLINES; KEAN DECLARATION
CASE NO. 3:11-CV-01080-JCS CONSOLIDATED WITH CASE NO. 3:11-CV-04203-JCS
4671966 V2

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Pursuant to Civil L.R. 6-2 and 7-

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ly

and request that the Initial Case Management

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Pending Case Management and ADR Deadlines (in the SCEA Action, Doc. 92), and (2) August 23,

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2011 Order Setting Initial Case Management Conference and ADR Deadlines (in the SEL Action,

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Consolidated Case No. 11-cv-04203, Doc. 4) be continued as set forth below. Pursuant to Civil L.R.

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6-2, this joint stipulation is based on the accompanying declaration of Abran J. Kean, which sets

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forth the following facts upon which the Parties agree:

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1.

The Parties request an extension to the case management deadlines, because of a

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scheduling conflict with the Initial Case Management Conference. The scheduling conflict regards a

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medical

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2.

The Parties further request that the case management deadlines for SEL, recently

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consolidated with SCEA in this Court, be set to track similar deadlines in this case.

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consolidation of case management deadlines will avoid unnecessary cost and delay, increase

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inefficiencies for the Parties, and provide economies for the Court.

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Such

3.
above be continued as follows:

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a. The last day to file a Fed. R. Civ. P. 26(f) Report or state objection in the Rule

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26(f) Report and file a Case Management Statement shall be continued from

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September 9, 2011 to September 16, 2011 and/or moved from December 1, 2011

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to September 16, 2011.

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b. The Initial Case Management Conference currently set for September 16, 2011 at

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1:30 p.m. shall be continued to September 23, 2011 at 1:30 p.m., and/or

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expedited from December 8, 2011 to September 23, 2011 at 1:30 p.m., or any

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later date or time convenient to the Court.

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JOINT STIPULATION TO CONTINUE DEADLINES; KEAN DECLARATION
CASE NO. 3:11-CV-01080-JCS CONSOLIDATED WITH CASE NO. 3:11-CV-04203-JCS

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4671966 v2

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c. The last day to complete initial disclosures shall be continued from September 9,

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2011 to October 3, 2011 and/or expedited from December 1, 2011 to October 3,

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2011. In the event that the Initial Case Management Conference is set for a date

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other than September 23, 2011, the parties agree to exchange initial disclosures

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no later than 10 days after the Initial Case Management Conference.

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4.

The following are the prior time modifications in the case, whether by stipulation or

Court order:

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a. On March 25, 2011, the Parties stipula

time to respond to

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b. On April 25, 2011, the Court vacated the April 25, 2011 deadline for SCEA to

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file a Second Amended Complaint that same day;

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c. On June 3, 2011, the Parties stipulated to extend ADR deadlines for 14 days to

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June 17, 2011 to permit the Parties to finalize the agreement set forth above; and

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d. On June 17, 2011, the Parties stipulated to extend the case management and ADR

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deadlines to permit the Parties to effectuate the severance of SEL from a related

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case and consolidate it with SCEA.

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REMAINDER OF THE PAGE LEFT INTENTIONALLY BLANK

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JOINT STIPULATION TO CONTINUE DEADLINES; KEAN DECLARATION
CASE NO. 3:11-CV-01080-JCS CONSOLIDATED WITH CASE NO. 3:11-CV-04203-JCS

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WHEREFORE, the Parties, by and through their respective counsel, hereby stipulate to and

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respectfully request this Court to enter an Order continuing or modifying the pending case
management deadlines, as stated above.

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Dated: September 8, 2011

Respectfully submitted,
WHITE FIELD, INC.

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By: /s/

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Steven W. Ritcheson
ATTORNEY FOR PLAINTIFF OLYMPIC
DEVELOPMENTS AG, LLC

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Dated: September 8, 2011

Respectfully submitted,

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SHOOK, HARDY & BACON L.L.P.

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By: /s/
Eric A. Buresh
Attorneys for Defendants and Counterclaimants
SONY COMPUTER ENTERTAINMENT
AMERICA LLC and SONY ELECTRONICS INC.

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Pursuant to General Order No. 45.X.B., the below filer attests that concurrence in the filing
of this document has been obtained from the above Signatories.

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Dated: September 8, 2011

__/s/___________________________________
Andrew L. Chang

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Dated:

9/9/2011

R NIA

UNIT
ED

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RT

FO

NO

________________________________________
HONORABLE JOSEPH C. SPEROo
Sper
UNITED STATES DISTRICT JUDGE
seph C.
Judge Jo

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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C
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D IS T IC T O
JOINT STIPULATION TO CONTINUER EADLINES; KEAN DECLARATION
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CASE NO. 3:11-CV-01080-JCS CONSOLIDATED WITH CASE NO. 3:11-CV-04203-JCS

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