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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1 6 KEKER & VAN NEST LLP STUART L. GASNER - # 164675 sgasner@kvn.com AJAY S. KRISHNAN - # 222476 akrishnan@kvn.com H. SAVALA NOLAN - #284212 snolan@kvn.com 633 Battery Street San Francisco, CA 94111-1809 Telephone: 415 391 5400 Facsimile: 415 397 7188 7 Attorneys for Plaintiff NEOCONIX, INC. 8 HARVEY SISKIND LLP Naomi Jane Gray ngray@harveysiskind.com 4 Embarcadero Center, 39th Floor San Francisco, CA 94111 Telephone: (415) 354-0100 Facsimile: (415) 391-7124 2 3 4 5 9 10 11 12 13 14 WOODCOCK WASHBURN LLP John W. Caldwell caldwell@woodcock.com Erich Falke efalke@woodcock.com Cira Centre, 12th Floor 2929 Arch Street Philadelphia, PA 19104-2891 Telephone: (215) 568-3100 Facsimile: (215) 568-3439 (pro hac vice pending) Attorneys for Defendants R&D CIRCUITS, INC., and R&D SOCKETS, INC. 15 UNITED STATES DISTRICT COURT 16 NORTHERN DISTRICT OF CALIFORNIA 17 18 NEOCONIX, INC., a Delaware corporation, Plaintiff, 19 20 21 22 23 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 24 25 26 27 28 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 1 1 WHEREAS, Plaintiff Neoconix, Inc., and Defendants R&D Circuits, Inc., and R&D 2 Sockets, Inc., (collectively, “the Parties”) desire a sufficient period of time in which to negotiate, 3 evaluate their respective positions, and meet and confer regarding their respective patent claims, 4 by and through counsel, the Parties hereby stipulate and agree to a 90-day stay of all case 5 management and related deadlines. 6 THEREFORE, subject to the Court’s approval, the Parties agree and stipulate as follows: 7 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. 8 days. Upon expiration of the 90-day stay, the following case deadlines will apply: 9 Item or Matter Original Deadline Extended Deadline 10 Plaintiffs’ Response to Defendants’ March 1, 2013 May 30, 2013 11 Answer and Counterclaims 12 File consent/declination to proceed February 28, 2013 June 7, 2013 13 before a United States Magistrate 14 Judge 15 Meet and confer regarding initial February 14, 2013 June 14, 2013 16 disclosures, early settlement, ADR 17 process selection, and discovery plan 18 File ADR certification, Stipulation to February 14, 2013 June 14, 2013, unless parties 19 the ADR Process, and/or Notice for jointly request assignment to 20 ADR Phone Conference particular ADR process prior to 21 May 15, 2013 22 File reports and complete initial 23 disclosures or state objections pursuant 24 to Federal Rule of Civil Procedure 25 26(f) 26 File Initial Case Management 27 Statement February 28, 2013 June 28, 2013 February 28, 2013 June 28, 2013 28 1 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 1 Initial Case Management Conference March 7, 2013 2 ______________ at __________ a.m/p.m. [a date and time on or 3 after July 12, 2013, that the Court 4 deems appropriate] 5 6 Respectfully submitted, 7 KEKER & VAN NEST LLP Dated: February 11, 2013 8 9 11 /s/ Stuart L. Gasner STUART L. GASNER AJAY S. KRISHNAN H. SAVALA NOLAN 12 Attorneys for Plaintiff NEOCONIX, INC. By: 10 13 Dated: February 11, 2013 HARVEY SISKIND LLP WOODCOCK WASHBURN LLP 14 15 By: 16 /s/ Naomi Jane Gray Naomi Jane Gray Attorney for Defendants R&D CIRCUITS, INC., and R&D SOCKETS, INC. 17 18 ATTORNEY ATTESTATION OF CONCURRENCE 19 I hereby attest that I have obtained Federal Defendants’ concurrence in this filing, 20 indicated by the signature of Federal Defendants’ counsel represented by a “conformed” signature 21 (“/s/”) within this e-filed document. 22 23 Dated: February 11, 2013 KEKER & VAN NEST LLP 24 25 By: /s/ Stuart L. Gasner STUART L. GASNER 26 27 28 2 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 1 [PROPOSED] ORDER 2 3 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 _____________________________________________________. 4 5 6 Dated: February 14, 2013 Honorable Maria-Elena James United States Magistrate Judge 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 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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