Suprema, Inc. v. SecuGen Corporation

Filing 31

STIPULATED ORDER EXTENDING DEADLINE FOR SELECTION AND ENGAGEMENT OF PRIVATE MEDIATOR re 30 Proposed Order filed by Suprema, Inc.. Signed by Judge Alsup on September 29, 2011. (whalc1, COURT STAFF) (Filed on 9/29/2011)

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D. James Pak (SBN 194331)
BAKER & McKENZIE LLP
12544 High Bluff Drive, Third Floor
San Diego, CA 92130-3051
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Tod Gamlen (SBN 83458)
BAKER & McKENZIE LLP
660 Hansen Way
Palo Alto, California 94304
Tel: [phone]
Fax: [phone]
[e-mail]

Brian E. Mitchell (SBN 199095)
Jigang Jin (SBN 239465)
MITCHELL + COMPANY, LAW OFFICES
4 Embarcadero Center, Suite 1400
San Francisco, CA 94111
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
[e-mail]

Steven M. Chasin (SBN 228723)
BAKER & McKENZIE LLP
815 Connecticut Avenue, N.W.
Washington, D.C. 20006
Tel: [phone]
Fax: [phone]
[e-mail]

Craig C. Daniel (SBN 212588)
David T.Wei (SBN 230729)
Art Sripipat (SBN 264753)
AXCEL LAW PARTNERS LLP
Four Embarcadero Center, 14th Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: 415-704-8804
[e-mail]
[e-mail]
[e-mail]

Attorneys for Plaintiff And CounterDefendant SUPREMA, INC.

Attorneys for Defendant And Counterclaimant
SECUGEN CORPORATION

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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SUPREMA, INC.,

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Plaintiff,
v.
SECUGEN CORPORATION,

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STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME FOR
SELECTION AND ENGAGEMENT OF
PRIVATE MEDIATOR

Defendant.

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Case No. 11-CV-02783 WHA

AND RELATED COUNTERCLAIMS

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STIPULATION

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Subject to Court approval, Plaintiff and Counter-defendant Suprema, Inc. and Defendant and
Counter-claimant SecuGen Corporation (collectively, the “Parties”), hereby stipulate, agree and

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Baker & McKenzie LLP
12544 High Bluff Drive,
Third Floor
San Diego, CA 921303051

Case No. 11-CV-02783 WHA
STIPULATION AND PROPOSED ORDER EXTENDING TIME FOR PARTIES’ SELECTION OF PRIVATE MEDIATOR
PALDMS/450052.2

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respectfully request that the September 30, 2011 deadline to select, clear, and engage a private

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mediator, as ordered in the Case Management Order, ¶ 2 (D.E 29), be extended by one week from

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Friday, September 30, 2011 to Friday, October 7, 2011.
The Parties are basing this stipulation on the following grounds, which they each believe

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constitute good cause. After the Case Management Conference held on September 15, 2011, various

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email communications were exchanged relating to mediation. The information in these

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communications had to be relayed by counsel to their respective clients, one of whom (Suprema) is

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located in Korea. As a result by Friday September 23 the Parties had not been able to agree on a

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mediator. On Monday, September 26, Craig Daniel, counsel for SecuGen responsible for mediator

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identification and selection for the defense, left for a pre-planned one week vacation and will not

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return until Monday, October 3 – this has made it challenging for the parties to complete the

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selection of the mediator by September 30. The parties jointly believe that a one-week extension of

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time will better facilitate the selection of appropriate mediator.

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This requested extension will not alter any other dates or deadlines set by the Court.

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September 27, 2011

Respectfully submitted,

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BAKER & McKENZIE LLP

MITCHELL + COMPANY, LAW OFFICES

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BY:

BY:

/s/ Tod L. Gamlen
Tod L. Gamlen

/s/Brian E Mitchell
Brian E Mitchell

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Attorneys for Plaintiff And Counter- Attorneys for Defendant And
Defendant SUPREMA, INC.
Counterclaimant SECUGEN
CORPORATION

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ORDER [PROPOSED]

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PURSUANT TO STIPULATION, IT IS SO ORDERED. There will be no more extensions.
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September ___, 2011.

_____________________________
Judge William Alsup

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Baker & McKenzie LLP
12544 High Bluff Drive,
Third Floor
San Diego, CA 921303051

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Case No. 11-CV-02783 WHA
STIPULATION AND PROPOSED ORDER EXTENDING TIME FOR PARTIES’ SELECTION OF PRIVATE MEDIATOR
PALDMS/450052.2

ATTESTATION OF CONCURRENCE BY TOD L. GAMLEN

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I, Tod L. Gamlen, hereby attest that I am one of the attorneys for Plaintiff And Counter-

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Defendant SUPREMA, INC. and, as the ECF user and filer of this document, I attest that, pursuant

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to General Order No. 45(X)(B), concurrence in the filing of this document has been obtained from

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Brian E Mitchell, the above signatory.

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Dated: September 28, 2011

By:

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/s/ Tod L. Gamlen
Tod L. Gamlen

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Baker & McKenzie LLP
12544 High Bluff Drive,
Third Floor
San Diego, CA 921303051

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Case No. 11-CV-02783 WHA
STIPULATION AND PROPOSED ORDER EXTENDING TIME FOR PARTIES’ SELECTION OF PRIVATE MEDIATOR
PALDMS/450052.2