Mycone Dental Supply Co., Inc. v. Creative Nail Design, Inc.

Filing 171

JOINT STIPULATION AND ORDER EXTENDING TIME TO EXCHANGE EXPERT REPORTS. Signed by Judge Richard Seeborg on 11/12/13. (cl, COURT STAFF) (Filed on 11/12/2013)

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VENABLE LLP
ADAM R. HESS (pro hac vice)
Email: [e-mail]
CHRISTOPHER T. LA TESTA (pro hac vice)
Email: [e-mail]
575 7th Street N.W.
Washington, D.C. 20004
Telephone: [phone]
Facsimile: [phone]
FREITAS TSENG & KAUFMAN LLP
CRAIG KAUFMAN (SBN 159458)
Email: [e-mail]
100 Marine Parkway, Suite 200
Redwood Shores, CA 94065
RACHEL KREVANS (CA SBN 116421)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: 415.268.7522
COLETTE R. VERKUIL (CA SBN 263630)
[e-mail]
JOSEPH K. KANADA (CA SBN 251401)
[e-mail]
MORRISON & FOERSTER LLP
755 Page Mill Road
Palo Alto, CA 94304-1018
Telephone: [phone]
Facsimile: 650.494.0792
Attorneys for Defendant and Counterclaimant
CREATIVE NAIL DESIGN, INC.

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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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MYCONE DENTAL SUPPLY CO., INC.
D/B/A/ KEYSTONE RESEARCH &
PHARMACUETICAL
Plaintiff,
v.
CREATIVE NAIL DESIGN, INC.,
Defendant.

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AND RELATED COUNTERCLAIM

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Case No.: 3:12-CV-00747-RS
JOINT STIPULATION AND
[PROPOSED] ORDER
EXTENDING TIME TO
EXCHANGE EXPERT REPORTS

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JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO EXCHANGE EXPERT REPORTS
CASE NO. 3:12-CV-00747-RS
pa-1614797

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Pursuant to Civil Local Rules 6-1 and 6-2, Defendant Creative Nail Design, Inc. (“CND”),

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Plaintiff Mycone Dental Supply Co., Inc. (“Keystone”), and Third-Party Defendants Young

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Nails, Inc., Cacee, Inc., and Nail Systems International, hereby stipulate and agree to extend the

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deadlines for discovery as follows:

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The deadline for the parties to exchange Reply Expert Reports is extended from
January 10, 2014 to January 31, 2014; and

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The deadline for the parties to exchange Rebuttal Expert Reports is extended from
December 13, 2013 to January 15, 2014;

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The deadline for fact discovery is extended from November 15, 2013 to
November 22, 2013;

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The deadline for the parties to exchange Opening Expert Reports is extended from
November 15, 2013 to November 22, 2013;

The close of expert discovery is extended from February 7, 2014 to February 19,
2014.

The parties request this extension for the reasons explained in the Declaration of Adam R.
Hess, submitted herewith. This extension will not affect any other deadlines set by the Court. In
addition, this extension will not affect any pre-trial or trial dates as no dates have been set for
trial.
Dated: November 12, 2013

MORRISON & FOERSTER LLP

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By: /s/ Colette R. Verkuil
Colette R. Verkuil
Attorneys for Defendant and Counterclaimant
CREATIVE NAIL DESIGN, INC.
FISH & RICHARDSON, PC

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By: /s/ John R. Lane
John M. Farrell
Attorneys for Plaintiff MYCONE DENTAL SUPPLY
CO., INC. D/B/A/ KEYSTONE RESEARCH &
PHARMACUETICAL and Third-Party Defendants

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JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO EXCHANGE EXPERT REPORTS
CASE NO. 3:12-CV-00747-RS
pa-1614797

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[PROPOSED] ORDER
PURSUANT TO THE FOREGOING STIPULATION, IT IS HEREBY ORDERED that

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the deadlines for the close of fact discovery and expert discovery and the deadlines for the parties

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to exchange their expert reports are extended and set as follows:

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1. The deadline for the parties to exchange Opening Expert Reports is extended from
November 15, 2013 to November 22, 2013.
2. The deadline for fact discovery is extended from November 15, 2013 to November
22, 2013.
3. The deadline for the parties to exchange Rebuttal Expert Reports is extended from
December 13, 2013 to January 15, 2014.
4. The deadline for the parties to exchange Reply Expert Reports is extended from
January 10, 2014 to January 31, 2014.
5. The close of expert discovery is extended from February 7, 2014 to February 19,
2014.

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IT IS SO ORDERED.

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Dated: 11/12/13

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Hon. Richard Seeborg
United States District Judge

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JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO EXCHANGE EXPERT REPORTS
CASE NO. 1:11-CV-04380-JBS-KMW
pa-1614797

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ATTESTATION
I, Colette R. Verkuil, am the ECF user whose ID and password are being used to file this

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document. I hereby attest that John R. Lane, counsel for Plaintiff and Third Party Defendants,

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has concurred in this filing.

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Dated: November 12, 2013

By:

/s/ Colette R. Verkuil___________________
Colette R. Verkuil

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JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO EXCHANGE EXPERT REPORTS
CASE NO. 1:11-CV-04380-JBS-KMW
pa-1614797

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