Illinois Union Insurance Company v. Intuitive Surgical, Inc.

Filing 194

STIPULATION AND ORDER re 193 STIPULATION WITH PROPOSED ORDER TO EXTEND MEDIATION DEADLINE FROM OCTOBER 15, 2016, TO NOVEMBER 30, 2016; filed by Intuitive Surgical, Inc. Signed by Judge Jon S. Tigar on October 13, 2016. (wsn, COURT STAFF) (Filed on 10/13/2016)

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ALLEN RUBY (SBN 47109)
RAOUL D. KENNEDY (SBN 40892)
JAMES P. SCHAEFER (SBN 250417)
SKADDEN, ARPS, SLATE, MEAGHER &
FLOM LLP
525 University Avenue, Suite 1400
Palo Alto, CA 94301
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiff/Defendant
INTUITIVE SURGICAL, INC.

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION

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12 ILLINOIS UNION INSURANCE COMPANY,
an Illinois corporation,
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Plaintiff,
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v.
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INTUITIVE SURGICAL, INC., a Delaware
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Defendant.

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[PROPOSED] ORDER.

Date:
May 26, 2016
Time:
2:00 Pm
Location: Courtroom 9
Trial Date: June 19, 2017

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JOINT STIPULATION TO EXTEND
MEDIATION DEADLINE FROM
OCTOBER 15, 2016, TO NOVEMBER 30,
2016; AND

Complaint Filed: October 21, 2013

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Case No. 3:13-cv-04863-JST
Hon. Jon S. Tigar

INTUITIVE SURGICAL, INC.,
Plaintiff,

CASE NO.: 3:15-cv-04834-JST
Complaint Filed: October 20, 2015

v.

ILLINOIS UNION INSURANCE COMPANY;
24 NAVIGATORS SPECIALTY INSURANCE CO.,
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Defendants.

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JOINT STIPULATION TO EXTEND MEDIATION DEADLINE FROM 10/15/16 TO 11/30/16

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Intuitive Surgical, Inc. (“Intuitive”) and Illinois Union Insurance Company (“Illinois Union”)

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jointly stipulate, pursuant to Civil Local Rules 6-1(b), 6-2, and 7-12, to extend the deadline for

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mediation of the consolidated actions numbered Case No. 3:13-cv-04863-JST and Case No. 3:15-cv-

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04834-JST, if it pleases this Court.

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WHEREAS, on July 26, 2016, the parties submitted a Joint Stipulation to Scheduling Order
which was approved and entered by the Court on July 28, 2016 (Dkt. 1861).

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WHEREAS, the Scheduling Order provided for a mediation deadline of October 15, 2016.

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WHEREAS, the parties have been conducting fact discovery in Case No. 3:15-cv-04834-

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JST, which has a fact discovery cut-off date of November 10, 2016.

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WHEREAS, the parties through their counsel have met and conferred, and agree that a

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private mediation is best conducted after the close of all fact discovery on November 10, 2016.

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NOW THEREFORE, the parties, through the undersigned counsel, hereby respectfully

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stipulate and request that this Court extend the mediation deadline to November 30, 2016, to allow

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the parties adequate time to conduct a private mediation in consolidated actions numbered Case No.

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3:13-cv-04863-JST and Case No. 3:15-cv-04834-JST, if this date is convenient to this Court. This

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change in the deadline for mediation will not change or affect any of the other dates in the

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Scheduling Order entered on July 28, 2016:

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Event

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//

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November 30, 2016

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October 15, 2016

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New Schedule

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Current Date

Mediation Deadline

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//

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Unless otherwise indicated, all docket citations refer to the ECF docket in Illinois Union Ins. Co. v. Intuitive Surgical,
Inc., No. 3:13-cv-04863-JST.
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JOINT STIPULATION TO EXTEND MEDIATION DEADLINE FROM 10/15/16 TO 11/30/16

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DATED: October 11, 2016

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SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP
By:

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/s/ James P. Schaefer
Attorneys for
INTUITIVE SURGICAL, INC.

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COZEN O’CONNER

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By:

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Pursuant to Civil Local Rule 5-1(i), the filer attests that concurrence in the filing of this
document has been obtained from the signatories above.

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/s/ Charles Wheeler
Attorneys for
ILLINOIS UNION INSURANCE COMPANY

/s/ James P. Schaefer
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JOINT STIPULATION TO EXTEND MEDIATION DEADLINE FROM 10/15/16 TO 11/30/16

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[PROPOSED] ORDER

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PURSUANT TO THE FOREGOING STIPULATION OF THE PARTIES, IT IS

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ORDERED THAT:
The Court enters the following modification to the case schedule for consolidated actions
numbered Case No. 3:13-cv-04863-JST and Case No. 3:15-cv-04834-JST:

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Event

Current Date

New Schedule

Mediation Deadline

October 15, 2016

November 30, 2016

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DATED: October 13, 2016

__________________________________
The Honorable Jon S. Tigar
United States District Court Judge

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JOINT STIPULATION TO EXTEND MEDIATION DEADLINE FROM 10/15/16 TO 11/30/16