Adobe Systems Incorporated v. Metrotech Solutions USA Inc. et al

Filing 51

STIPULATION AND ORDER re 50 to Extend Deadline to Complete Mediation filed by Adobe Systems Incorporated. Case Management Statement due by 1/11/2018. Further Case Management Conference reset for 1/18/2018 10:30 AM in Courtroom 5, 17th Floor, San Francisco. Signed by Judge Edward M. Chen on 11/16/17. (bpfS, COURT STAFF) (Filed on 11/16/2017)

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JOHNSON & PHAM, LLP
Christopher Q. Pham, SBN: 206697
E-mail: [e-mail]
Nicole Drey Huerter, SBN: 250235
E-mail: [e-mail]
Hung Q. Pham, SBN: 276613
E-mail: [e-mail]
6355 Topanga Canyon Boulevard, Suite 326
Woodland Hills, California 91367
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Plaintiff

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LAW OFFICES OF GEORGE A. SHOHET, A PROF. CORP.
George A. Shohet, SBN: 112697
E-mail: [e-mail]
9100 Wilshire Boulevard, Suite 720E
Beverly Hills, California 90212
Telephone:
[phone]
Facsimile:
[phone]

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Attorney for Defendants

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ADOBE SYSTEMS INCORPORATED, a
Delaware Corporation,
Plaintiff,

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v.

Case No.: 3:14-cv-04871-EMC
STIPULATION TO EXTEND
DEADLINE TO COMPLETE
MEDIATION

METROTECH SOLUTIONS USA INC., a
Delaware Corporation; 9199-6546 QUEBEC
INC., a Canadian Quebecois Corporation
doing business as METROTECH
SOLUTIONS INC., METROTECH
SOLUTIONS and METROTECH; and DOES
2-10, Inclusive,
Defendants.
Plaintiff ADOBE SYSTEMS INCORPORATED (“Plaintiff”), by and through its counsel
of record, and Defendants METROTECH SOLUTIONS USA INC.; 9199-6546 QUEBEC INC.
d/b/a METROTECH SOLUTIONS INC., METROTECH SOLUTIONS and METROTECH;
9188-0047 QUEBEC INC. d/b/a UKTECH STORE; and 9199-6587 QUEBEC INC. d/b/a IT
-1STIPULATION TO EXTEND MEDIATION DEADLINE – CASE NO.: 3:14-cv-04871-EMC

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FACTORY (collectively “Defendants”), by and through their counsel of record, hereby stipulate

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and agree as follows:

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RECITALS

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On August 24, 2017, the Court ordered the Parties to complete mediation by no later than
November 22, 2017 (D.E. 48).

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On September 22, 2017, the ADR office appointed Linda Joy Kattwinkel, Esq., to serve
as mediator.

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The mediator and the Parties then arranged for mediation to take place on November 13,
2017.

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On October 13, 2017, the mediator alerted the Parties that she had developed a conflict

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that required her to be out of town that week and that the mediation would need to be

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rescheduled.

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There is no date prior to the current mediation deadline of November 22, 2017, that is

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available for the mediator, all Parties, and their counsel. Instead, the date of December 12, 2017,

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has been confirmed to reschedule the mediation.

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-2STIPULATION TO EXTEND MEDIATION DEADLINE – CASE NO.: 3:14-cv-04871-EMC

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AGREEMENT

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Accordingly, Plaintiff and Defendants hereby stipulate and respectfully request the Court

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extend the mediation deadline to December 15, 2017, and delay ruling on Plaintiff’s pending

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Motion for Contempt until sometime thereafter. The Parties shall submit a joint report regarding

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mediation by no later than December 22, 2017.

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DATED: November 13, 2017

JOHNSON & PHAM, LLP

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By: /s/ Nicole Drey Huerter
Nicole Drey Huerter, Esq.
Attorneys for Plaintiff
ADOBE SYSTEMS INCORPORATED

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DATED: November 13, 2017

LAW OFFICES OF GEORGE A. SHOHET,
A PROF. CORP.

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By: /s/ George A. Shohet
George A. Shohet, Esq.
Attorney for Defendants
METROTECH SOLUTIONS USA INC.; 91996546 QUEBEC INC., d/b/a METROTECH
SOLUTIONS INC., METROTECH SOLUTIONS
and METROTECH; 9188-0047 QUEBEC INC.
d/b/a UKTECH STORE; and 9199-6587 QUEBEC
INC. d/b/a IT FACTORY

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NO

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R NIA

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RT
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O

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Further CMC reset from 12/7/17 to 1/18/18
at 10:30 a.m. An update joint CMC statement
due 1/11/18.
ISTRIC
ES D
TC
11/16/17
DATED: ____________________
______________________________
AT
T
HON. EDWARD M. CHEN
United States District Judge RDERED
S SO O
I California
Northern District of T I S MODIFIED
A
. Chen

dward M

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Judge E

FO

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IT IS SO ORDERED.

LI

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H

-3RN
STIPULATION TO EXTEND MEDIATION DEADLINE – CASE NO.:E3:14-cv-04871-EMCC
F
D IS T IC T O
R

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The Parties shall submit a joint regarding the mediation by no later than December 22, 2017.

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Pursuant to Stipulation, the deadline for mediation is extended to December 15, 2017.

UNIT
ED

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[PROPOSED] ORDER