Stetson University, Inc.-v-Frederick Acker et al

Filing 20

STIPULATION AND ORDER CONTINUING ADR COMPLIANCE AND INITIAL CASE MANAGEMENT CONFERENCE DEADLINES by Hon. William Alsup granting 19 Stipulation.(whalc1, COURT STAFF) (Filed on 6/30/2016)

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1 2 3 4 5 Lynde Selden III (SBN 207513) lselden@keeginharrison.com Robert L. Harrison (SBN 76710) rharrison@keeginharrison.com KEEGIN HARRISON SCHOPPERT SMITH & KARNER LLP 1000 Fourth Street, Suite 600 San Rafael, California 94901 Telephone: (415) 456-4000 Facsimile: (415) 456-9021 6 7 Attorneys for Plaintiff Stetson University, Inc. 8 9 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 10 11 12 13 14 15 16 17 STETSON UNIVERSITY, INC., a Florida not for profit corporation, Plaintiff, v. FREDERICK G. ACKER, as personal representative of the Estate of C. Paul Johnson a/k/a Chauncey Paul Johnson; THE C. PAUL JOHNSON FAMILY CHARITABLE FOUNDATION, an entity of unknown form; and FREDERICK G. ACKER, as Trustee of the C. Paul Johnson 2003 Trust, CASE NO. C 16-1905-WHA STIPULATION AND [PROPOSED] ORDER CONTINUING ADR COMPLIANCE AND INITIAL CASE MANAGEMENT CONFERENCE DEADLINES Judge: Hon. William H. Alsup 18 19 Defendants. 20 21 22 23 24 25 26 27 28 Order re: DM_US 74123072-1.021074.0017 STIPULATION RE: CONTINUING ADR AND CMC DEADLINES CASE NO. C 16-1905-WHA 1 2 WHEREAS the Complaint in the action captioned Stetson University, Inc. v. Frederick G. Acker, et al., No. C 16-1905, was filed in this Court on April 11, 2016; 3 WHEREAS a First Amended Complaint in this action was filed on May 5, 2016; 4 WHEREAS, this action was re-assigned to U.S. District Judge William H. Alsup on June 5 6 23, 2016; WHEREAS not all defendants have been served with process, but all parties desire to 7 establish uniform dates for events in this action, including a case management conference and 8 the date by which all defendants must respond to the First Amended Complaint; 9 WHEREAS plaintiff’s counsel will be in Europe from June 29 to July 21, 2016; one 10 counsel for defendants Frederick G. Acker, as personal representative of the Estate of C. Paul 11 Johnson a/k/a Chauncey Paul Johnson and Frederick G. Acker, Trustee of the C. Paul Johnson 12 2003 Trust will be out of the country from June 29 to July 10, 2016; and another counsel for 13 defendants will be on vacation from August 5 to August 21, 2016 14 THEREFORE, IT IS HEREBY STIPULATED THAT: 15 1. The last day to meet and confer regarding initial disclosures, early settlement, 16 ADR process selection, and discovery plan, as well as to file ADR Certifications and related 17 Stipulations or Notices shall be continued to July 25, 2016; 18 2. The last day to file Rule 26(f) reports, complete initial disclosures or state 19 objections in Rule 26(f) reports, and file a Joint Case Management Statement shall be continued 20 to August 2, 2016; 21 22 23 3. The Initial Case Management Conference currently scheduled for July 14, 2016 shall be continued to August 25, 2016 at 11:00 a.m.; and 4. All defendants’ deadline to answer, move or otherwise respond to the First 24 Amended Complaint shall be the same as the deadline (yet to be determined) for defendant The 25 C. Paul Johnson Family Charitable Foundation to answer, move or otherwise respond to the 26 Complaint. 27 28 CASE NO. C 16-1905-WHA DM_US 74123072-1.021074.0017 1 1 2 3 Dated: June 29, 2016 Respectfully submitted, KEEGIN HARRISON SCHOPPERT SMITH & KARNER LLC 4 5 /s/ Lynde Selden III Lynde Selden III (SBN 207513) lselden@keeginharrison.com Robert L. Harrison (SBN 76710) rharrison@keeginharrison.com 1000 Fourth Street, Suite 600 San Rafael, California 94901 Telephone: (415) 456-4000 Facsimile: (415) 456-9021 Attorneys for Plaintiff Stetson University, Inc. 6 7 8 9 10 11 Dated: June 29, 2016 McDERMOTT WILL & EMERY LLP 12 /s/ A. Marisa Chun A. Marisa Chun 275 Middlefield Road, Suite 100 Menlo Park, CA 94025 Telephone: (650) 815-7400 Facsimile: (650) 815-7401 Mchun@mwe.com 13 14 15 16 Attorneys for Defendants Frederick G. Acker, as personal representative of the Estate of C. Paul Johnson a/k/a Chauncey Paul Johnson and Frederick G. Acker, as Trustee for The C. Paul Johnson 2003 Trust 17 18 19 20 21 22 In accordance with Civil Local Rule 5-1(i)(3) of this Court, I, Lynde Selden III, attest to the fact that concurrence in the filing of this document has been obtained from the other signatory which shall serve in lieu of his or her signature on the document. 23 24 /s/ Lynde Selden III LYNDE SELDEN III 25 26 27 28 CASE NO. C 16-1905-WHA DM_US 74123072-1.021074.0017 2 1 2 [PROPOSED] ORDER The above STIPULATION AND [PROPOSED] ORDER CONTINUING ADR 3 COMPLIANCE AND INITIAL CASE MANAGEMENT CONFERENCE DEADLINES is 4 APPROVED. 5 1. The last day to meet and confer regarding initial disclosures, early settlement, 6 ADR process selection, and discovery plan, as well as to file ADR Certifications and related 7 Stipulations or Notices shall be continued to July 25, 2016; 8 9 10 11 12 13 2. The last day to file Rule 26(f) reports, complete initial disclosures or state objections in Rule 26(f) reports, and file a Joint Case Management Statement shall be continued to August 2, 2016; 3. The Initial Case Management Conference currently scheduled for July 14, 2016 shall be continued to August 25, 2016 at 11:00 a.m.; and 4. All defendants’ deadline to answer, move or otherwise respond to the First 14 Amended Complaint shall be the same as the deadline (yet to be determined) for defendant The 15 C. Paul Johnson Family Charitable Foundation to answer, move or otherwise respond to the 16 Complaint. 17 18 IT IS SO ORDERED. Dated: June 30, 2016. 19 HONORABLE WILLIAM H. ALSUP UNITED STATES DISTRICT JUDGE 20 21 22 23 24 25 26 27 28 CASE NO. C 16-1905-WHA DM_US 74123072-1.021074.0017 3

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