Neoconix, Inc. v. R&D Circuits, Inc.

Filing 13

ORDER by Magistrate Judge Maria-Elena James granting in part and denying in part #12 Stipulation re 90 Day Stay of All Case Deadlines. (rmm2S, COURT STAFF) (Filed on 2/14/2013)

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KEKER & VAN NEST LLP
STUART L. GASNER - # 164675
[e-mail]
AJAY S. KRISHNAN - # 222476
[e-mail]
H. SAVALA NOLAN - #284212
[e-mail]
633 Battery Street
San Francisco, CA 94111-1809
Telephone:
415 391 5400
Facsimile:
415 397 7188

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Attorneys for Plaintiff NEOCONIX, INC.

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HARVEY SISKIND LLP
Naomi Jane Gray
[e-mail]
4 Embarcadero Center, 39th Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]

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WOODCOCK WASHBURN LLP
John W. Caldwell
[e-mail]
Erich Falke
[e-mail]
Cira Centre, 12th Floor
2929 Arch Street
Philadelphia, PA 19104-2891
Telephone:
[phone]
Facsimile:
[phone]
(pro hac vice pending)

Attorneys for Defendants R&D CIRCUITS, INC.,
and R&D SOCKETS, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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NEOCONIX, INC., a Delaware corporation,
Plaintiff,

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v.
R&D CIRCUITS, INC., a New Jersey
corporation; R&D SOCKETS, INC., a
Delaware Corporation,
Defendants.

Case No. 12-cv-06153 MEJ
STIPULATION AND [PROPOSED]
ORDER RE 90-DAY STAY OF ALL CASE
DEADLINES [CIVIL L.R. 7-11 AND 7-12]

Date Filed: December 4, 2012
Trial Date: None Set

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STIPULATION AND [PROPOSED] ORDER RE 90-DAY STAY OF ALL CASE DEADLINES [CIVIL
L.R. 7-11 AND 7-12]
Case No. 12-cv-06153 MEJ
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WHEREAS, Plaintiff Neoconix, Inc., and Defendants R&D Circuits, Inc., and R&D

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Sockets, Inc., (collectively, “the Parties”) desire a sufficient period of time in which to negotiate,

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evaluate their respective positions, and meet and confer regarding their respective patent claims,

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by and through counsel, the Parties hereby stipulate and agree to a 90-day stay of all case

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management and related deadlines.

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THEREFORE, subject to the Court’s approval, the Parties agree and stipulate as follows:

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All proceedings in this case, including but not limited to discovery, shall be stayed for 90
the parties shall file a joint status report for the Court's review.

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days. Upon expiration of the 90-day stay, the following case deadlines will apply:

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Item or Matter

Original Deadline

Extended Deadline

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Plaintiffs’ Response to Defendants’

March 1, 2013

May 30, 2013

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Answer and Counterclaims

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File consent/declination to proceed

February 28, 2013

June 7, 2013

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before a United States Magistrate

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Judge

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Meet and confer regarding initial

February 14, 2013

June 14, 2013

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disclosures, early settlement, ADR

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process selection, and discovery plan

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File ADR certification, Stipulation to

February 14, 2013

June 14, 2013, unless parties

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the ADR Process, and/or Notice for

jointly request assignment to

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ADR Phone Conference

particular ADR process prior to

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May 15, 2013

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File reports and complete initial

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disclosures or state objections pursuant

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to Federal Rule of Civil Procedure

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26(f)

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File Initial Case Management

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Statement

February 28, 2013

June 28, 2013

February 28, 2013

June 28, 2013

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STIPULATION AND [PROPOSED] ORDER RE 90-DAY STAY OF ALL CASE DEADLINES [CIVIL
L.R. 7-11 AND 7-12]
Case No. 12-cv-06153 MEJ

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Initial Case Management Conference

March 7, 2013

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______________ at __________
a.m/p.m. [a date and time on or

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after July 12, 2013, that the Court

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deems appropriate]

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Respectfully submitted,

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KEKER & VAN NEST LLP

Dated: February 11, 2013
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/s/ Stuart L. Gasner
STUART L. GASNER
AJAY S. KRISHNAN
H. SAVALA NOLAN

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Attorneys for Plaintiff NEOCONIX, INC.

By:

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Dated: February 11, 2013

HARVEY SISKIND LLP
WOODCOCK WASHBURN LLP

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By:

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/s/ Naomi Jane Gray
Naomi Jane Gray
Attorney for Defendants R&D CIRCUITS,
INC., and R&D SOCKETS, INC.

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ATTORNEY ATTESTATION OF CONCURRENCE
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I hereby attest that I have obtained Federal Defendants’ concurrence in this filing,
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indicated by the signature of Federal Defendants’ counsel represented by a “conformed” signature
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(“/s/”) within this e-filed document.
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Dated: February 11, 2013

KEKER & VAN NEST LLP

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By:

/s/ Stuart L. Gasner
STUART L. GASNER

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STIPULATION AND [PROPOSED] ORDER RE 90-DAY STAY OF ALL CASE DEADLINES [CIVIL
L.R. 7-11 AND 7-12]
Case No. 12-cv-06153 MEJ

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[PROPOSED] ORDER

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All case management and related deadlines are STAYED for 90 days. The parties shall
file a joint status report at the end of the 90 day stay.

IT IS SO ORDERED _____________________________________________________.

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Dated: February 14, 2013

Honorable Maria-Elena James
United States Magistrate Judge

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STIPULATION AND [PROPOSED] ORDER RE 90-DAY STAY OF ALL CASE DEADLINES [CIVIL
L.R. 7-11 AND 7-12]
Case No. 12-cv-06153 MEJ