Peerless Insurance Company v. Cleer Gear LLC et al

Filing 18

JOINT STIPULATION FOR CONTINUANCE OF DATES; ORDER. Signed by Judge Maxine M. Chesney on March 24, 2014. (mmclc2, COURT STAFF) (Filed on 3/24/2014)

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JAMES J.S. HOLMES (STATE BAR NO. 126779)
[e-mail]
SEDGWICK LLP
801 South Figueroa Street, 19th Floor
Los Angeles, CA 90017-5556
Telephone:
213.426.6900
Facsimile:
213.426.6921
BENJAMIN E. SHIFTAN (STATE BAR NO. 265767)
[e-mail]
SEDGWICK LLP
333 Bush Street, 30th Floor
San Francisco, CA 94104-2834
Telephone:
415.781.7900
Facsimile:
415.781.2635
Attorneys for Plaintiff
PEERLESS INSURANCE COMPANY

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DEMIÁN I. OKSENENDLER (STATE BAR NO. 233416)
[e-mail]
MANNION & LOWE
655 Montgomery Streey, Suite #1200
San Francisco, CA 94111
Telephone: [phone]
Facsimile: 415.733.1054

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Attorneys for Defendants
CLEER GEAR, LLC and PETER TSOU dba CLEER
GEAR

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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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PEERLESS INSURANCE COMPANY,
Plaintiff,

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v.
CLEER GEAR, LLC and PETER TSOU dba
CLEER GEAR,

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Case No. 3:14-cv-00135 MMC
JOINT STIPULATION FOR
CONTINUANCE OF DATES;
[PROPOSED] ORDER
Judge:
Hon. Maxine M. Chesney
Courtroom: 7

Defendants.
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DOCS/18598871v1

3:14-cv-00135 MMC
JOINT STIPULATION FOR CONTINUANCE OF DATES; [PROPOSED] ORDER

WHEREAS, pursuant to the court’s order and pursuant to the parties’ stipulations, the

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above-captioned action currently has the following deadlines in place:

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•

Deadline to confer pursuant to FRCP 26(f): March 21, 2014.

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Deadline for Cleer Gear to respond to Peerless’complaint: March 26, 2014.

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Deadline to file stipulated request or motion for order enlarging or shortening time which
affects initial case management conference: March 28, 2014.

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Deadline to make written request to reschedule dates set forth in Judge Chesney’s Case
Management Conference Order: April 1, 2014.

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Deadline for Discovery Plan: April 4, 2014.

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•

Deadline for Initial Disclosures: April 4, 2014.

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•

Deadline to file and serve request for telephonic appearance at case management
conference: April 4, 2014.

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Deadline to file and serve a Joint Case Management Statement: April 4, 2014;

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Case Management Conference: April 11, 2014.
WHEREAS, the parties agree that all deadlines identified herein (and any others

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identified by the Court) should be continued by three weeks in order to allow the parties to

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continue the settlement negotiations that they have commenced.
WHEREAS, the parties hope that these settlement negotiations will result in a dismissal

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of this action, such that further litigation is not necessary.
WHEREAS, the parties have never before asked the court to continue any dates in this

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action.
STIPULATION

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NOW THEREFORE, it is agreed and stipulated by and between:

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1.

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Plaintiff PEERLESS INSURANCE COMPANY, by and through its counsel of

record James J.S. Holmes; and
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Defendants CLEER GEAR, LLC and PETER TSOU dba CLEER GEAR, by and

through their counsel of record, Demián I. Oksenendler, that

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DOCS/18598871v1

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3:14-cv-00135 MMC

JOINT STIPULATION FOR CONTINUANCE OF DATES; [PROPOSED] ORDER

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The following dates previously set by order of the Court be continued and modified in each of

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the above-captioned actions as follows:
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Deadline to confer pursuant to FRCP 26(f) shall be continued to: April 11, 2014 or any
date thereafter that the Court orders.

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•

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Deadline for Cleer Gear to respond to Peerless’ complaint shall be continued to: April
16, 2014 or any date thereafter that the Court orders.

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•

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Deadline to file stipulated request or motion for order enlarging or shortening time which

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affects initial case management conference shall be continued to: April 18, 2014 or any

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date thereafter that the Court orders.
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Deadline to make written request to reschedule dates set forth in Judge Chesney’s Case

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Management Conference Order shall be continued to: April 22, 2014 or any date

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thereafter that the Court orders.
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Deadline for Discovery Plan shall be continued to: April 25, 2014 or any date thereafter
that the Court orders.

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•

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Deadline for Initial Disclosures shall be continued to: April 25, 2014 or any date
thereafter that the Court orders.

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•

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Deadline to file and serve request for telephonic appearance at case management

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conference shall be continued to: April 25, 2014 or any date thereafter that the Court

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orders.
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Deadline to file and serve a Joint Case Management Statement shall be continued to:
April 25, 2014 or any date thereafter that the Court orders;

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•

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Case Management Conference shall be continued to: May 2, 2014 or any date thereafter
that the Court orders; and

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•

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Any other existing dates in the above-referenced matters that are not mentioned herein

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but identified by the Court shall be continued for 21 days or longer to any date the Court

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orders.

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IT IS SO STIPULATED.

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DOCS/18598871v1

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3:14-cv-00135 MMC

JOINT STIPULATION FOR CONTINUANCE OF DATES; [PROPOSED] ORDER

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DATED: March 24, 2014

SEDGWICK LLP

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By:

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/s/ James J.S. Holmes
James J.S. Holmes
Benjamin E. Shiftan
Attorneys for Plaintiff
PEERLESS INSURANCE COMPANY

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DATED: March 24, 2014

MANNION & LOWE

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By:

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/s/ Demián I. Oksenendler
Demián I. Oksenendler
Attorneys for Defendants
CLEER GEAR, LLC and PETER TSOU dba CLEER
GEAR

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Filer’s Attestation: Pursuant to Civil Local Rule 5-1(i)(3) regarding signatures, James J.S.
Holmes hereby attests that concurrence in the filing of this document has been obtained.

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: March 24 2014
__,
HONORABLE MAXINE M. CHESNEY
United States District Court Judge

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DOCS/18598871v1

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3:14-cv-00135 MMC

JOINT STIPULATION FOR CONTINUANCE OF DATES; [PROPOSED] ORDER