Ronpak, Inc. v. Electronics For Imaging, Inc.

Filing 27

STIPULATION AND ORDER re 26 STIPULATION WITH PROPOSED ORDER Request for Order Continuing Case Management Conference filed by Ronpak, Inc. Case Management Statement due by 1/7/2015. Initial Case Management Conference set for 1/21/2015 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on December 4, 2014. (wsn, COURT STAFF) (Filed on 12/5/2014)

1
2
3
4
5
6
7
8
9
10
11
12

KENNETH E. KELLER (SBN 71450) [e-mail]
GARTH A. ROSENGREN (SBN 215732) [e-mail]
KELLER, SLOAN, ROMAN & HOLLAND LLP
555 Montgomery Street, 17th Floor
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiff RONPAK, INC.
IVO LABAR (SBN 203492) [e-mail]
FRANK BUSCH (SNB 258288) [e-mail]
KERR & WAGSTAFFE LLP
101 Mission Street, 18th Floor
San Francisco, California 94105
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Defendant
ELECTRONICS FOR IMAGING, INC.

13
14

THE UNITED STATES DISTRICT COURT
15

FOR THE NORTHERN DISTRICT OF CALIFORNIA
16
17

RONPAK, INC., a New Jersey corporation

18
19

Plaintiff,
vs.

20
21
22
23
24
25
26

ELECTRONICS FOR IMAGING, INC., a
Delaware corporation,
Defendant.

)
)
)
)
)
)
)
)
)
)
)

Case No. 3:14-cv-04058 JST
JOINT REQUEST FOR ORDER
CONTINUING CASE MANAGEMENT
CONFERENCE
Current CMC Date: December 20, 2014
Requested CMC Date: January 21, 2015

Plaintiff Ronpak, Inc. and Defendant Electronics for Imaging, Inc. (collectively referred to
herein as “the Parties”) hereby stipulate and agree as follows:
The Case Management Conference in this case is initially scheduled for December 17, 2014

27

at 2:00 p.m. The parties are currently making progress in their settlement discussions and request

28

1
________________________________________________________________________________
STIPULATED REQUEST FOR ORDER
CONTINUING CASE MANAGEMENT CONFERENCE
CASE NO.: 3:14-cv-04058 JST

1

that the Court continue the Case Management Conference so that they may complete their

2

negotiations.

3

The parties have made one prior request to modify the Court’s calendar in this matter, which

4

was to continue the date for the hearing on Defendant’s Motion to Dismiss. They made that request

5

was made for same reason as this one – to permit the conclusion of settlement discussions. The

6

Court granted that request in its December 2, 2014 Order, moving the hearing from December 4,

7

2017 to January 8, 2015. See, DE 25.
The parties do not believe that re-setting the Case Management Conference will have a

8
9
10

material effect on the timing of this action. Moreover, the likelihood that the parties can resolve
their dispute at this early stage merits the delay caused by the requested continuance.
THEREFORE, the parties jointly request that the Court reset the Case Management

11
12

Conference thirty days (30) from December 17, 2014 to January 21, 2015 or as soon as it can be

13

heard by this Court, with the parties’ Joint Case Management Conference Statement due 10 court

14

days prior.

15
16
17

Date: December 2, 2014

KELLER, SLOAN, ROMAN & HOLLAND LLP

18

By: ___/s/ Kenneth E. Keller________________
Kenneth E. Keller
Attorneys for Plaintiff RONPAK, INC.

19
20
21

Date: December 2, 2014

KERR & WAGSTAFFE LLP

22

By: ___/s/ Ivo Labar_______________________
Ivo Labar
Attorneys for Defendant
ELECTRONICS FOR IMAGING, INC.

23
24
25
26

///

27

///

28

2
_________________________________________________________________________________
STIPULATED REQUEST FOR ORDER
CONTINUING CASE MANAGEMENT CONFERENCE
CASE NO.: 3:14-cv-04058 JST

1
2
3

I hereby attest that I have been authorized by Ivo Labar to execute on his behalf this
Stipulated Request for Order Continuing Case Management Conference.
Executed on this 4th day of December, 2014 at San Francisco, California.

4
5
6

______/s/ Kenneth E. Keller______
Kenneth E. Keller

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

3
_________________________________________________________________________________
STIPULATED REQUEST FOR ORDER
CONTINUING CASE MANAGEMENT CONFERENCE
CASE NO.: 3:14-cv-04058 JST

[PROPOSED] ORDER

1

Having considered the foregoing stipulation of the parties, the Court orders the Case

2
3

Management Conference in the instant matter, continued to January 21, 2015, at 2:00 p.m. in

4

Courtroom 9, with the parties’ Joint Case Management Conference Statement to be filed 10 days

5

prior.

13

ER

H

12

RT

11

R NIA

n S. T
u d ge J o
J

NO

10

i ga r

FO

9

A

8

_______________________________________
DERED
SO OR
S JUDGE JON S. TIGAR
HONORABLE
IT I
UNITED STATES DISTRICT COURT JUDGE

LI

Dated: _____________, 2013
December 4, 2014

UNIT
ED

7

S

IT IS SO ORDERED.

RT
U
O

6

ISTRIC
ES D
TC
T
TA

N

F
D IS T IC T O
R

C

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

4
_________________________________________________________________________________
STIPULATED REQUEST FOR ORDER
CONTINUING CASE MANAGEMENT CONFERENCE
CASE NO.: 3:14-cv-04058 JST