Guards Polo Club Holdings LTD v. Reid et al

Filing 38

ORDER Denying Stipulation for Stay and Continuance of the Pre-Trial Schedule & for a New Trial Date. Signed by Judge Samuel Conti on 11/14/11. (tdm, COURT STAFF) (Filed on 11/15/2011)

CONNON WOOD SCHEIDEMANTLE LLP
1 NICHOLAS P. CONNON, State Bar No. 150815
[e-mail]
2 ROBERT A. de BY, admitted Pro Hac Vice
[e-mail]
3 EDWARD S. PAK, State Bar No. 271853
[e-mail]
4 35 East Union Street, Suite C
Pasadena, California 91103
5 Telephone: [phone]
Facsimile:
[phone]
6
Attorneys for Plaintiff Guards Polo Club Holdings Ltd.
7
FREUND & BRACKEY LLP
8 THOMAS A. BRACKEY II, State Bar No. 162279
[e-mail]
9 CRAIG A. HUBER, State Bar No. 159763
[e-mail]
10 STEPHEN P. CRUMP, State Bar No. 251712
[e-mail]
11 427 North Camden Drive
Beverly Hills, CA 90210
12 Telephone: [phone]
Facsimile:
[phone]
13
Attorneys for Defendant Margaret Goodman Reid
14
UNITED STATES DISTRICT COURT
15
NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION
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GUARDS POLO CLUB HOLDINGS LTD.,
Plaintiff,

19
vs.

20

MEGAN GOODMAN REID, MICHAEL
21 KOSKIE (a/k/a MICHAEL MCGREGOR),
AND JOHN/JANE DOES 1-20
22
Defendants.
23

CASE NO. 11-cv-01817 SC
[Assigned to the Honorable Samuel Conti]
JOINT STIPULATION TO STAY AND
CONTINUE THE PRE-TRIAL
SCHEDULE & FOR A NEW TRIAL
DATE IN ORDER TO ATTEMPT TO
FINALIZE A SETTLEMENT
JUDGE: Hon. Samuel Conti

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364.01

JOINT STIPULATION TO STAY AND CONTINUE THE PRE-TRIAL SCHEDULE & FOR A
NEW TRIAL DATE – 11-cv-01817 SC

1

Plaintiff Guards Polo Club Holdings Ltd. (“Plaintiff”) and Defendant Megan Goodman

2 Reid (“Defendant”) hereby enter into this Stipulation and request that the Court set a new date for
3 trial, presently set for May 31, 2012 at 9:30 a.m., on a date at the end of September 2012 and to
4 stay and continue the Pre-Trial Schedule set forth in the Court’s Status Conference Order, dated
5 August 26, 2011, accordingly. This request is being made because the parties participated in a full
6 day mediation on October 18, 2011, as a result of which they are currently in serious and advanced
7 discussions to resolve the case. Specifically, Defendant Reid needs 60 days to explore certain
8 financial arrangements related to any settlement. Further, the parties anticipate that they may need
9 an additional 60 days to finalize any settlement reached and to allow Defendant Reid to secure
10 financing that will permit her to consummate the terms of any settlement.
11

The parties would like to devote their full energies towards resolving this case since they

12 believe the prospects of resolution are good and such a stay and continuance will avoid the parties
13 incurring legal fees that could be driven by pending deadlines. Moreover, while the parties are
14 focused on resolution of this entire matter, they believe it is preferable to avoid serving the Doe 1
15 defendant, and request is therefore also made to extend the time to effectuate service on the Doe 1
16 defendant.
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THEREFORE, BASED UPON THE FOREGOING, PLAINTIFF AND DEFENDANT

18 DO HEREBY STIPULATE AS FOLLOWS AND REQUEST THE COURT ENTER AN ORDER
19 CONSISTENT WITH THE FOLLOWING:
20

1.

The trial date be continued to September 24, 2012, or on such date and at such time

21 as is convenient for the Court thereafter, and the pre-trial schedule set forth in the Status
22 Conference Order be continued such that each date mentioned there is reset to the equivalent day
23 four months later than mentioned in the Status Conference Order.
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2.

The date by which Plaintiff must effectuate service on the Doe 1 defendant be

25 extended from December 29, 2011 to February 1, 2012.
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-2JOINT STIPULATION TO STAY AND CONTINUE THE PRE-TRIAL SCHEDULE & FOR A
NEW TRIAL DATE – 11-cv-01817 SC

364.01

CONNON WOOD SCHEIDEMANTLE LLP
1 NICHOLAS P. CONNON, State Bar No. 150815
[e-mail]
2 ROBERT A. de BY, admitted Pro Hac Vice
[e-mail]
3 EDWARD S. PAK, State Bar No. 271853
[e-mail]
4 35 East Union Street, Suite C
Pasadena, California 91103
5 Telephone: [phone]
Facsimile:
[phone]
6
Attorneys for Plaintiff Guards Polo Club Holdings Ltd.
7
FREUND & BRACKEY LLP
8 THOMAS A. BRACKEY II, State Bar No. 162279
[e-mail]
9 CRAIG A. HUBER, State Bar No. 159763
[e-mail]
10 STEPHEN P. CRUMP, State Bar No. 251712
[e-mail]
11 427 North Camden Drive
Beverly Hills, CA 90210
12 Telephone: [phone]
Facsimile:
[phone]
13
Attorneys for Defendant Margaret Goodman Reid
14
UNITED STATES DISTRICT COURT
15
NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION
16
17
18

GUARDS POLO CLUB HOLDINGS LTD.,
Plaintiff,

19
vs.

20

MEGAN GOODMAN REID, MICHAEL
21 KOSKIE (a/k/a MICHAEL MCGREGOR),
AND JOHN/JANE DOES 1-20
22
Defendants.
23

CASE NO. 11-cv-01817 SC
[Assigned to the Honorable Samuel Conti]
[PROPOSED] ORDER FOR A STAY AND
CONTINUANCE OF THE PRE-TRIAL
SCHEDULE & FOR A NEW TRIAL
DATE
JUDGE: Hon. Samuel Conti

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27
28

364.01

ORDER FOR A STAY AND CONTINUANCE OF THE PRE-TRIAL SCHEDULE AND FOR A
NEW TRIAL DATE; CASE NO. 11-cv-01817 SC

1

The parties to the above-entitled action having agreed to a new date for trial currently set

2 for May 31, 2012 at 9:30 a.m., and to stay and continue the pre-trial schedule as described in the
3 Status Conference Order, dated August 26, 2011.
4

PURSUANT TO STIPULATION, IT IS ORDERED that the new trial date is set for

5 September 24, 2012 at 9:30 a.m., before the Honorable Judge Samuel Conti and that the pre-trial
6 schedule and dates contained in the Status Conference Order are each continued for a period of
7 120 days from the dates set forth therein. Further, Defendant shall have until February 1, 2012 to
8 serve the Doe 1 defendant.

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Judge Samuel Conti

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DATED: October ___, 2011

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November 14, 2011

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-2ORDER FOR A STAY AND CONTINUANCE OF THE PRE-TRIAL SCHEDULE AND FOR A
NEW TRIAL DATE; CASE NO. 11-cv-01817 SC

364.01