Business Integration Technology, Inc. v. Mulesoft,Inc., et al

Filing 109

STIPULATION AND ORDER re 108 STIPULATION to Enlarge Time for Parties to Serve Their Rule 26 Disclosures and submit Joint Case Management Order; Declaration of Jennifer A. Betz filed by Business Integration Technology, Inc. Case Management Statement due by 6/7/2012. Case Management Conference set for 6/14/2012 04:15 PM in Courtroom E, 15th Floor, San Francisco. Signed by Judge Elizabeth D Laporte on 5/31/2012. (kns, COURT STAFF) (Filed on 6/4/2012)

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PHILIP L. WILLMAN (Admitted Pro Hac)
JENNIFER A. BETZ (Admitted Pro Hac)
MOSER & MARSALEK, P.C.
200 North Broadway, Suite 700
St. Louis, Missouri 63102
Telephone:
[phone]
Facsimile:
[phone]
FRANCIS TORRENCE (State Bar No,. 154653)
WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP
525 Market Street, 17th Floor
San Francisco, California 94105-2725
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiff,
BUSINESS INTEGRATION TECHNOLOGY, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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BUSINESS INTEGRATION
TECHNOLOGY, INC.,

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Plaintiff,
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v.
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MULESOFT, INC. & PHILIP T. BRADLEY,
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Defendants.
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Case No.: 3:11-cv-04782 EDL
Hon. Elizabeth D. Laporte
REVISED STIPULATION TO ENLARGE
TIME FOR PARTIES TO SERVE THEIR
RULE 26 DISCLOSURES AND SUBMIT
JOINT CASE MANAGEMENT ORDER;
DECLARATION OF JENNIFER A. BETZ;
[PROPOSED ORDER]

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REVISED STIPULATION TO ENLARGE TIME FOR PARTIES TO SERVE THEIR RULE 26 DISCLOSURES AND SUBMIT
JOINT CASE MANAGEMENT ORDER; [PROPOSED ORDER]

884600.1

Case No. 3:11-cv-04782 EDL

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REVISED STIPULATION AND [PROPOSED] ORDR TO ENLARGE TIME FOR
PARTIES TO SERVE THEIR RULE 26 DISCLOSURES AND SUBMIT THEIR JOINT
CASE MANAGEMENT ORDER
Plaintiff, Business Integration Technology, Inc. (hereinafter “BIT”), hereby states as
follows:
RECITALS

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A.

Pursuant to Order from this Court, the parties are to serve the Rule 26(f) disclosures

and submit a joint case management order on May 29, 2012. (Doc 97.)

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B.

Plaintiff seeks from this Court an extension of both deadlines to June 7, 2012.

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C.

Defendants do not object to this extension.

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D.

To comply with the Court rules, both parties also consent to moving the Initial Case

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Management Conference from Tuesday, June 5, 2012 to Thursday, June 14, 2012, at 4:15 p.m.

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PDT, at the United States District Court, Courtroom E, 15th Floor, 450 Golden Gate Avenue, San

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Francisco, California, before Judge Elizabeth D. Laporte.

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STIPULATION

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Accordingly, the parties stipulate and agree as follows:

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1.

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Plaintiff and Defendants shall serve their Rule 26(f) Disclosures and submit a Joint

Proposed Case Management Order no later than June 7, 2012.
2.

The Initial Case Management Conference is set for Thursday, June 14, 2012, at 4:15

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p.m. PDT, at the United States District Court, Courtroom E, 15th Floor, 450 Golden Gate Avenue,

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San Francisco, California, before Judge Elizabeth D. Laporte.

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Respectfully submitted,

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Dated: May 30, 2012
CLAASSEN, a Professional Corporation

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By: /s/ John S. Claassen
John S. Claassen, Esq.
Attorneys for Defendants
MULESOFT, INC. and PHILIP T. BRADLEY

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REVISED STIPULATION TO ENLARGE TIME FOR PARTIES TO SERVE THEIR RULE 26 DISCLOSURES AND SUBMIT
JOINT CASE MANAGEMENT ORDER; [PROPOSED ORDER]

884600.1

Case No. 3:11-cv-04782 EDL

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Respectfully submitted,

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Dated: May 30, 2012
MOSER & MARSALEK, P.C.

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By: /s/ Philip L. Willman (admitted Pro Hac)
/s/ Jennifer A Betz (admitted Pro Hac)
Attorneys for Plaintiff
BUSINESS INTEGRATION TECHNOLOGY, INC.

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Respectfully submitted,
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Dated: May 30, 2012
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WILSON, ELSER. MOSKOWITZ, EDELMAN & DICKER LLP

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By: /s/ Francis Torrence
Attorney for Plaintiff
BUSINESS INTEGRATION TECHNOLOGY, INC.

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REVISED STIPULATION TO ENLARGE TIME FOR PARTIES TO SERVE THEIR RULE 26 DISCLOSURES AND SUBMIT
JOINT CASE MANAGEMENT ORDER; [PROPOSED ORDER]

884600.1

Case No. 3:11-cv-04782 EDL

[PROPOSED ORDER]

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For good cause shown, the above Stipulation of the Parties is adopted as the Order of the

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Elizabeth D.eLaporte D. La
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May 31, 2012
Date: ___________________

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REVISED STIPULATION TO ENLARGE TIME FOR PARTIES TO SERVE THEIR RULE 26 DISCLOSURES AND SUBMIT
JOINT CASE MANAGEMENT ORDER; [PROPOSED ORDER]

884600.1

Case No. 3:11-cv-04782 EDL

DECLARATION OF JENNIFER A. BETZ, ESQ.

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I, Jennifer A. Betz, state as follows:

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I am admitted pro hac vice to practice before this Court in this matter. I am one of

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the counsel of record for Plaintiff Business Integration Technology, Inc., in the above-captioned

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action. Unless otherwise indicated, I have personal knowledge of the facts alleged herein and court

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and would testify competently thereto if asked to do so.

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2.

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personal conflicts.

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3.

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Plaintiff is seeking this enlargement of time to accommodate professional and

I do not believe that the enlargement of time requested through the parties’

stipulation will affect any existing deadlines imposed by the Court, or status of case.
I declare under penalty of perjury under the laws of the United States that the foregoing is
true and correct. Executed this 30th Day of May, 2012, at St. Louis, Missouri.

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By: /s/ Jennifer A Betz (admitted Pro Hac)
JENNIFER A. BETZ, ESQ.

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REVISED STIPULATION TO ENLARGE TIME FOR PARTIES TO SERVE THEIR RULE 26 DISCLOSURES AND SUBMIT
JOINT CASE MANAGEMENT ORDER; [PROPOSED ORDER]

884600.1

Case No. 3:11-cv-04782 EDL

CERTIFICATION

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I, Francis J. Torrence, Esq., am the ECF User whose identification and password are being

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used to file the REVISED STIPULATION TO ENLARGE TIME FOR PARTIES TO SERVE

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THEIR RULE 26(f) DISCLOSURS AND SUBMIT A JOINT CASE MANAGEMENT ORDER

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(Local Civ. R. 6-1(b)); DECLARATION OF JENNIFER A. BETZ; and [PROPOSED] ORDER. In

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compliance with General Order 4.X.B., I hereby attest that John S. Claassen, Esq. has concurred in

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this filing.

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Respectfully submitted,

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Dated: May 30, 2012
WILSON, ELSER. MOSKOWITZ, EDELMAN & DICKER LLP

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By: /s/ Francis Torrence
Attorney for Plaintiff
BUSINESS INTEGRATION TECHNOLOGY, INC.

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REVISED STIPULATION TO ENLARGE TIME FOR PARTIES TO SERVE THEIR RULE 26 DISCLOSURES AND SUBMIT
JOINT CASE MANAGEMENT ORDER; [PROPOSED ORDER]

884600.1

Case No. 3:11-cv-04782 EDL