Tangle, Inc. v. Magic Time International Ltd. et al

Filing 46

ORDER granting 45 STIPULATION to Continue Case Management Conference Date and Early Neutral Evaluation Deadline. Case Management Statement due by 3/16/2016. Case Management Conference and Motion Hearing re: 30 Motion to Dismiss set for 3/23/2016 02:00 PM in Courtroom 2, 17th Floor, San Francisco before Hon. William H. Orrick. Signed by Judge William H. Orrick on 01/13/2016. (jmdS, COURT STAFF) (Filed on 1/13/2016)

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16

Lewis Emery Hudnell, III (Bar No. 218736)
[e-mail]
HUDNELL LAW GROUP P.C.
800 w. El Camino Real Suite 180
Mountain View, CA 94040
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendants
MAGIC TIME INTERNATIONAL, LTD.
BROWN SALES & MARKETING LLC
John W. Carpenter (Cal. Bar No. 221708)
LAW OFFICES OF JOHN W. CARPENTER
LLC
829 Baronne Street
New Orleans, LA 70113
T: 415.577.0698
F: 866.410.6248
Email: [e-mail]
VICTORIA E. BRIEANT (Bar No. 141519)
Law Office of Victoria E. Brieant
4000 Ponce de Leon Boulevard, Suite 470
Coral Gables, FL 33146
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Plaintiff
TANGLE INC.

17

UNITED STATES DISTRICT COURT

18

NORTHERN DISTRICT OF CALIFORNIA

19

SAN FRANCISCO DIVISION

20

TANGLE INC.,

21

Plaintiff,

22

V.

23
24
25

Case No.: 3:15-cv-2802-WHO

MAGIC TIME INTERNATIONAL LTD.; and
BROWN SALES & MARKETING LLC

STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE
DATE AND EARLY NEUTRAL
EVALUATION DEADLINE

Defendants.

26
27
28

STIPULATION TO CONTINUE
CASE MANAGEMENT CONFERENCE DATE
AND EARLY NEUTRAL EVALUATION
DEADLINE

CASE NO.: 3:15-CV-2802-WHO

1
2
3
4
5
6
7
8
9
10

Plaintiff Tangle, Inc. and Defendants Magic Time International, Ltd. Brown Sales &
Marketing LLC hereby enter into this Stipulation Continuing Case Management Conference and
Early Neutral Evaluation Deadlines with reference to the following facts:
WHEREAS, on June 22, 2015, the Court issued an Order Setting a Case Management
Conference for September 24, 2015;
WHEREAS, on September 8, 2015, the Court issued an Order continuing the date for the
Case Management Conference to October 7, 2015;
WHEREAS, on September 17, 2015 the Court issued an Order continuing the date for the
Case Management Conference to November 10, 2015;

11

WHEREAS, on November 5, 2015 the Court issued an Order continuing the date for the

12

Case Management Conference and the hearing date for Defendants’ motion to dismiss (Dkt. No.

13

30) to December 8, 2015;

14

WHEREAS, on December 1, 2015 the Court issued an Order continuing the date for the

15

Case Management Conference and the hearing date for Defendants’ motion to dismiss (Dkt. No.

16

30) to January 26, 2016;

17
18
19
20
21
22
23

WHEREAS, on January 4, 2016 the Court issued an Order setting the deadline for the
Early Neutral Evaluation to January 25, 2016;
WHEREAS, on January 5, 2016 the Court issued an Order appointing Mark LeHocky as
the ENE Evaluator for this case;
WHEREAS, Mr. LeHocky has informed the parties that he has limited availability to
complete the Early Neutral Evaluation before the current deadline;
WHEREAS, the Plaintiff’s counsel and/or representative are unable to attend the Early

24

Neutral Evaluation on the dates proposed by Mr. LeHocky (January 15, 18, and 25, 2016) to

25

complete the Evaluation;

26

WHEREAS, the parties and Mr. LeHocky conducted a teleconference on January 11,

27

2016 to discuss scheduling and agreed that the parties and Mr. LeHocky are available to conduct

28

STIPULATION TO CONTINUE
CASE MANAGEMENT CONFERENCE
DATE AND EARLY NEUTRAL
EVALUATION DEADLINE

CASE NO.: 3:15-CV-2802-WHO

2

1
2

the Early Neutral Evaluation on February 22, 2016;
WHEREAS, the parties agrees that that it is in the interest of justice to further continue the

3

Case Management Conference to allow the parties additional time to discuss settlement after the

4

Early Neutral Evaluation;

5

WHEREAS, lead counsel for the parties are available on Tuesday, March 22, 2016 for a

6

Case Management Conference and a hearing on Defendants’ motion to dismiss (Dkt. No. 30) and

7

to complete the Early Neutral Evaluation on or before that date;

8
9
10

WHEREAS, the parties respectfully request that the Court continue the Case Management
Conference and the hearing on Defendants’ motion to dismiss (Dkt. No. 30) to Tuesday, March
22, 2016 and continue the Early Neutral Evaluation deadline to February 23, 2016.

11
12

Dated: January 12, 2016

LAW OFFICE OF VICTORIA E. BRIEANT

13
14

By: /s/ Victoria E. Brient
Victoria E. Brient

15

Attorney for
TANGLE INC.

16
17

Dated: January 12, 2016

LAW OFFICES OF JOHN W. CARPENTER LLC

18
19

By: /s/ John W. Carpenter
John W. Carpenter

20

Attorneys for
TANGLE INC.

21
22

Dated: January 12, 2016

HUDNELL LAW GROUP

23
24

By: /s/ Lews E. Hudnell, III
Lews E. Hudnell, III

25

Attorneys for
MAGIC TIME INTERNATIONAL, LTD.
BROWN SALES & MARKETING LLC

26
27
28

STIPULATION TO CONTINUE
CASE MANAGEMENT CONFERENCE
DATE AND EARLY NEUTRAL
EVALUATION DEADLINE

CASE NO.: 3:15-CV-2802-WHO

3

ATTORNEY ATTESTATION

1
2

I, Lews E. Hudnell, III, attest that concurrence in the filing of this document has been

3

obtained from any signatories indicated by a “conformed” signatured (/s/) within this e-filed

4

documents. I declare under penalty of perjury under the laws of the United States of America that

5

the foregoing is true and correct.

6

Dated: January 12, 2015

HUDNELL LAW GROUP

7
8

By: /s/ Lews E. Hudnell, III
Lews E. Hudnell, III

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

STIPULATION TO CONTINUE
CASE MANAGEMENT CONFERENCE
DATE AND EARLY NEUTRAL
EVALUATION DEADLINE

CASE NO.: 3:15-CV-2802-WHO

4

1

[PROPOSED] ORDER

2

Having read and considered the Parties’ Stipulation to Continue Case Management

3

Conference and the Early Neutral Evaluation deadline,

4

PURSUANT TO STIPULATION, the Court hereby resets the Case Management

5

Conference and the hearing date on Defendants’ motion to dismiss (Dkt. No. 30) to March 23,

6

2016 in Courtroom 2, 17th Floor, 450 Golden Gate Avenue, San Francisco, CA 94102 and the

7

deadline to complete Early Neutral Evaluation to February 23, 2016.

8
9

January 13
Dated: ____________________, 2016

10

_______________________________
The Honorable William H. Orrick
JUDGE OF THE U.S. DISTRCT COURT

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

STIPULATION TO CONTINUE
CASE MANAGEMENT CONFERENCE
DATE AND EARLY NEUTRAL
EVALUATION DEADLINE

CASE NO.: 3:15-CV-2802-WHO

5