The Regents of the University of California v. The Corporate Executive Board Company

Filing 13

STIPULATION AND ORDER re 12 STIPULATION re 11 Case Management Scheduling Order and to Continue Case Management Conference and Related Deadlines filed by The Regents of the University of California. Case Management Statement due by 8/19/2014. Case Management Conference set for 8/26/2014 10:00 AM in Courtroom 10, 19th Floor, San Francisco. Signed by Judge Vince Chhabria on 6/11/2014. (knm, COURT STAFF) (Filed on 6/12/2014)

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1 2 3 4 5 6 OLIVIER A. TAILLIEU (SBN 206546) o@taillieulaw. com RAFFIV. ZEROUNIAN (SBN 236388) rz@taillieulaw.com THE TAILLIEU LAW FIRM LLP 450 N. Roxbury Drive, Suite 700 Beverly Hills, CA 90210 Telephone: (310) 651-2440 Facsimile: (310)651-2439 Attorneys for Plaintiff The Regents ofthe University of California 7 8 IN THE UNITED STATES DISTRICT COURT 9 FOR THE NORTHERN DISTRICT OF CALIFORNIA 10 THE REGENTS OF THE UNIVERSITY OF 11 Plaintiff, 12 13 THE CORPORATE EXECUTIVE BOARD 14 Case No. 3:14-cv-00885-VC CALIFORNIA, a California corporation, COMPANY, a Delaware corporation, and SECOND JOINT STIPULATION PURSUANT TO LOCAL RULES 16-2 AND 7-12 TO CONTINUE CASE MANAGEMENT CONFERENCE AND RELATED DEADLINES AND [PROPOSED] ORDER AS MODIEFIED DOES 1-10, 15 Defendants. 16 17 18 Pursuant to Civil Local Rules 16-2 and 7-12, plaintiffThe Regents of the University of 19 California ("Plaintiff') and defendant The Corporate Executive Board Company d/b/a CEB 20 ("Defendant") hereby jointly request that the Court continue the Case Management Conference 21 currently set for June 27,2014 at 10:30a.m. to August 29,2014 at 10:30 a.m., or as soon 22 thereafter as counsel may be heard, with the initial case management and ADR deadlines 23 rescheduled accordingly from the new Case Management Conferencedate. 24 Procedural Background 25 Plaintiff filed its Complaint against Defendant on February 27,2014. On the same day, 26 U.S. Magistrate Judge Nathanael Cousins issued his OrderSetting Initial Case Management 27 Conference and ADR Deadlines, which set the initial Case Management Conference on May 28, 28 2014 at 10:00 a.m. On March 28,2014, Plaintiff filed a Declination to Magistrate Judge SECOND STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND TPROPOSEDl ORDER Case No. 3:14-cv-00885-VC 1 Jurisdiction, and this case was reassigned to the Honorable Vince Chhabria on May 7,2014. On 2 May 12,2014, this Court issued its Order Setting Initial Case Management Conference,which set 3 the initial Case Management Conference on June 27,2014 at 10:30 a.m. 4 Reasons for Request to Continue Case Management Conference Dates 5 Good cause exists for this requested continuance, which would allow Plaintiff and 6 Defendant to continue to direct their resources toward a settlement of this action. Plaintiff held off 7 on serving the Complaint upon Defendant to allow the parties to focus on settlement. Since 8 Plaintifffiled its lawsuit, the parties have devoted considerable energy, including numerous 9 settlement conferences between the parties' principals, in an effort to reach an amicable resolution 10 oftheir dispute. Although differences remain between Plaintiff and Defendant, the parties will 11 continue to have further settlement discussions over the next month or so. Ifthe dispute is not 12 resolved within that timeframe, Plaintiff will serve the Complaint Until then, the parties would 13 prefer to devote their energy and resources on working towards an amicable resolution of the 14 dispute rather than focusing on litigation. 15 Defendant makes this stipulation without prejudice to or waiver of any of its claims or 16 defenses in this action, including those that Defendant may assert in response to Plaintiffs 17 Complaint. 18 Prior Time Modifications and Effect of Requested Modification 19 On May 6,2014, the parties filed a Joint Stipulation Pursuant to Local Rules 16-2 and 7-12 20 to Continue Case Management Conference and Related Deadlines and [Proposed] Order (Dkt. 8), 21 but the [Proposed] Order was never signed. The stipulated extensionwill have no effect on the rest 22 of the schedule in this action. 23 NOW, THEREFORE, the parties to this action, through their respective counsel AGREE 24 TO AND HEREBY STIPULATE to reschedule the Case Management Conference and related 25 deadlines as follows: 26 27 28 STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND fPROPOSEDl ORDER Case No. 3:14-cv-00885-VC 1 1. the Case Management Conference currently set for June 27, 2014 at 10:30 a.m. shall be 2 continued to August 29, 2014 at 10:30 a.m., or as soon thereafter as counsel may be 26 10:00 3 heard; and 4 5 2. the initial case management and ADR deadlines shall be rescheduled accordingly from the new Case Management Conference date. O 6 Dated: June __, 2014 Respectfully submitted: 7 THE TAILLIEU LAW FIRM LLP Olivier A. Taillieu Raffi V. Zerounian 8 9 10 Attorneys/for Plaintiff 11 The Regents of the University of California 12 13 KIRKLAND & ELLIS LLP Claudia Ray 14 Dai.eCendali, P.C 15 16 c ^e By: Attorneys for Defendant 17 The Corporate Executive Board Company d/b//! CEB 18 19 [PROPOSED! ORDER AS MODIFIED 21 22 Dated: June 11 ,2014 25 S UNIT ED 24 RT U O PURSUANT TO STIPULATION, IT IS SO ORDERED. 23 S DISTRICT TE C TA DERED SO OR IT IS DIFIED AS MO R NIA 20 NO United States District Judgebr ia hha ER STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND fPROPOSEDl ORDER A H 28 ince C LI RT 27 J u d ge V FO The Honorable Vince Chhabria 26 N C OF D I S T 3:14-cv-00885-VC Case No. RICT

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