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

Filing 52

STIPULATION AND ORDER Staying Litigation for Additional 90 Days re #51 : Case Management Statement due by 7/10/2012. Case Management Conference set for 7/17/2012 at 10:00 AM in Courtroom E, 15th Floor, San Francisco. Signed by Magistrate Judge Elizabeth D. Laporte on 4/19/2012. (kns, COURT STAFF) (Filed on 4/19/2012)

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Roger D. Wintle (SBN 142484)
THE HERITAGE LAW GROUP, A P.C.
152 North Third Street
San Jose, California 95112
Tel: [phone]
Fax: [phone]
Email: [e-mail]

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Attorney for Plaintiff
BRADFORD TECHNOLOGIES, INC.
GREENBERG TRAURIG, LLP
Kurt A. Kappes, CA Bar No. 146384
[e-mail]
Matthew L. Reagan, CA Bar No. 261832
[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
METRO NATIONAL FINANCIAL, LLC
KARMA TECHNOLOGIES, LLC
RODNEY NEWMAN
JOHN DAVID BIGGERS
NCV SOFTWARE

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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BRADFORD TECHNOLOGIES, INC.,
Plaintiff,
v.

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NCV SOFTWARE.com, et al.,
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Defendants.

STIPULATION AND ORDER TO STAY LITIGATION
FOR ADDITIONAL 90 DAYS

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Case No. 3:11-CV-04621 (EDL)
STIPULATION AND ORDER TO STAY
LITIGATION FOR ADDITIONAL 90
DAYS AS MODIFIED

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

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WHEREAS, Plaintiff Bradford Technologies, Inc. (“Plaintiff”) and Defendants Metro

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National Financial, LLC (“Metro Financial”), Karma Technologies, LLC (“Karma”), Rodney

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Newman (“Newman”), John David Biggers (“Biggers”) and NCV Software (collectively,

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“Defendants”) (representing all defendants who have been served in this matter), have agreed to
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participate in private mediation of this matter before a neutral;
WHEREAS, the parties have tentatively scheduled a mediation with the Hon. Jamie
Jacobs-May with Judicial Arbitration and Mediation Services on June 15, 2012;
WHEREAS, the parties wish to avoid the burden and expense of the litigation pending
the outcome of their private mediation;
IT IS HEREBY STIPULATED and AGREED by and between the foregoing parties in

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this matter, through their respective counsel of record, as follows:
1.

This action should be stayed until July 15, 2012, to permit the parties to retain

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experts to review and compare the source code, software platform and other information relative

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or germane to the issues raised in this case and to participate in private mediation before a

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neutral.

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2.

If the stay is entered, then the scheduled April 24, 2012 hearing before the court

shall be vacated. The motions to dismiss filed by Defendants Metro Financial, Newman and

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Karma, as well as the case management conference before the Court, shall be continued to a date
to be set at a later time (but not during the pendency of the stay).
3.

The parties have agreed upon an appropriate form of protective order, which shall

be submitted to the court.
4.

Any party may request an order from the Court to modify or lift this stay upon

good cause after consultation with counsel for the other parties to this action.

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STIPULATION AND ORDER TO STAY LITIGATION
FOR ADDITIONAL 90 DAYS

Case No. 3:11-CV-04621-EDL
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IT IS SO STIPULATED.

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Dated: April 16, 2012

THE HERITAGE LAW GROUP

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/S/ ROGER D. WINTLE

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Roger D. Wintle
Attorney for Plaintiff: Bradford Technologies, Inc

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Dated: April 16, 2012

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
Matthew L. Reagan

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Attorneys for Defendants
METRO NATIONAL FINANCIAL, LLC
KARMA TECHNOLOGIES, LLC
RODNEY NEWMAN
JOHN DAVID BIGGERS
NCV SOFTWARE

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ELIZABETH D. LAPORTE
ERED
United StatesO ORD Judge
S Magistrate
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DIFIED

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D. Lapo

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STIPULATION AND ORDER TO STAY LITIGATION
FOR ADDITIONAL 90 DAYS

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April 19, 2012

UNIT
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Dated:

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
The Initial Case Management Conference is continued to July 17, 2012 at 10:00 a.m. Updated Case Management
Conference Statements are due by July 10, 2012.

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