Bradford Technologies, Inc. v. NCV Software.com et al

Filing 134

STIPULATION AND ORDER AS MODIFIED to Continue the Case Management Conference for 60 days: Case Management Statement due by 4/16/2013. Further Case Management Conference set for 4/23/2013 03:00 PM in Courtroom E, 15th Floor, San Francisco. Signed by Judge Elizabeth D Laporte on 2/11/2013. (knm, COURT STAFF) (Filed on 2/12/2013)

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GREENBERG TRAURIG, LLP
Kurt A. Kappes, CA Bar No. 146384
[e-mail]
Greg Sperla, CA Bar No. 278062
[e-mail]
1201 K Street, Suite 1100
Sacramento, California 95814
Telephone: [phone]
Facsimile: [phone]
ANDERSON & KARRENBERG
Thomas R. Karrenberg (admitted pro hac vice)
[e-mail]
Heather M. Sneddon (admitted pro hac vice)
[e-mail]
Samantha J. Slark (admitted pro hac vice)
[e-mail]
50 West Broadway, Suite 700
Salt Lake City, Utah 84101
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
KARMA TECHNOLOGIES, LLC
JOHN DAVID BIGGERS
Roger D. Wintle (SBN 142484)
Jill Schachter (SBN 278100)
THE HERITAGE LAW GROUP, A P.C.
152 North Third Street
San Jose, California 95112
Tel: [phone]
Fax: [phone]

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Attorney for Plaintiff
BRADFORD TECHNOLOGIES, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA
BRADFORD TECHNOLOGIES, INC.,

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Plaintiff,
v.
NCV SOFTWARE.com, et al.,
Defendants.

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Case No. 3:11-CV-04621 (EDL)
STIPULATION AND ORDER TO
CONTINUE CASE MANAGEMENT
CONFERENCE FOR 60 DAYS
AS MODIFIED

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STIPULATION AND ORDER TO CONTINUE CASE
MANAGEMENT CONFERENCE FOR 60 DAYS

Case No. 3:11-CV-04621-EDL
Page 1

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WHEREAS, the Court entered a Stipulated Order Regarding Defendants Karma

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Technologies, LLC’s And John David Biggers’ Motion For An Order To Show Cause Why

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Plaintiff, Jeffrey Bradford And Roger Wintle Should Not Be Held In Contempt of Court And For
Further Relief And Sanctions on December 6, 2012 (the “Sanctions Order”);

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WHEREAS, pursuant to the Sanctions Order, Defendants are conducting expedited

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discovery concerning their three source code discs and the extent to which they were accessed,

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reviewed, copied, downloaded and/or saved by Bradford Technologies, Inc., Jeffrey Bradford

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and/or AppraisalWorld, Inc., in violation of the Stipulated Protective Order in this matter;

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WHEREAS, in anticipation of the completion of the foregoing expedited discovery
within two (2) months, the Court scheduled a case management conference for February 19,

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2013, at 10:00 a.m.;
WHEREAS, Defendants have not yet been able to complete the expedited discovery

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contemplated by the Sanctions Order due, in part, to the fact that Defendants’ retained,

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independent expert was not given access to Mr. Bradford’s personal laptop until January 21,

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2013, to obtain a forensic image for analysis:

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WHEREAS, Defendants’ independent experts need additional time to complete their
analyses, and Defendants need additional time to schedule and conduct relevant depositions once

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the experts finish their analyses;

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WHEREAS, to permit Defendants sufficient time to conduct and complete their

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expedited discovery, the parties wish to continue the case management conference scheduled for

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February 19, 2013, by approximately sixty (60) days;

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IT IS HEREBY STIPULATED and AGREED by and between the foregoing parties in
this matter, through their respective counsel of record, as follows:

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STIPULATION AND ORDER TO CONTINUE CASE
MANAGEMENT CONFERENCE FOR 60 DAYS

Case No. 3:11-CV-04621-EDL
Page 2

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at 3:00 p.m.
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The case management conference should be continued until April 22, 2013, to

permit Defendants to complete the expedited discovery contemplated by the Sanctions Order,
and for their experts to complete their analyses.

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2.

Any party may request an order from the Court to expedite the case management

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conference, or to otherwise seek expedited relief from Court, for good cause.
IT IS SO STIPULATED.
Dated: February 11, 2013

ANDERSON & KARRENBERG, P.C.

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By: /s/ Heather M. Sneddon

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- and -

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GREENBERG TRAURIG, LLP
Kurt A. Kappes
Greg Sperla

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Attorneys for Defendants
KARMA TECHNOLOGIES, LLC
JOHN DAVID BIGGERS

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Dated: February 11, 2013

THE HERITAGE LAW GROUP

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By: /s/ Jill Schachter

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Attorneys for Plaintiff
BRADFORD TECHNOLOGIES, INC.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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STIPULATION AND ORDER TO CONTINUE CASE
MANAGEMENT CONFERENCE FOR 60 DAYS

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ELIZABETH D.ORDERED
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Dated: February 11, 2013

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Case No. 3:11-CV-04621-EDL
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