ICE Consulting, Inc. et al v. Jensen

Filing 92

STIPULATION AND ORDER as to 78 MOTION to Dismiss Defendant and Counter-Claimant Gavin Jensen's Second, Third, Fourth, and Fifth Counterclaims; Memorandum of Points and Authorities in Support Thereof. Case Management Statement du e by 12/8/2016. Further Case Management Conference reset for 12/15/2016 01:30 PM in Courtroom 5, 17th Floor, San Francisco. Motion Hearing reset for 12/15/2016 01:30 PM in Courtroom 5, 17th Floor, San Francisco before Edward M. Chen. Signed by Judge Edward M. Chen on 11/10/16. (bpfS, COURT STAFF) (Filed on 11/10/2016)

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NOSSAMAN LLP
VERONICA M. GRAY (SBN 72572)
[e-mail]
ANDREW C. CRANE (SBN 285211)
[e-mail]
18101 Von Karman Avenue, Suite 1800
Irvine, CA 92612
Telephone: [phone]
Facsimile: 949.833.7878
S. ASHAR AHMED (SBN 256711)
[e-mail]
50 California Street, 34th Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: 415.398.2438
Attorneys for Plaintiffs and Counter-Defendants
ICE Consulting, Inc.; Uzair Sattar;
and Derick Needham

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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ICE CONSULTING, INC., UZAIR
SATTAR, and DERICK NEEDHAM

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Plaintiffs and CounterDefendants,

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vs.
GAVIN JENSEN,
Defendant and CounterClaimant.

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Case No: 3:16-cv-04349-EMC
STIPULATION TO CONTINUE
CASE MANAGEMENT
CONFERENCE AND HEARING
ON ICE CONSULTING, INC.’S
MOTION TO DISMISS AND
[PROPOSED] ORDER
Current Date of CMC: Dec. 8, 2016
Proposed New Date
Of CMC:
Dec. 15, 2016
Trial: Not Set

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Case No. 3:16-cv-04349-EMC

STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND HEARING ON
ICE CONSULTING, INC.’S MOTION TO DISMISS AND [PROPOSED] ORDER
31336711.v1

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Pursuant to Local Rule 6-2, Plaintiffs ICE Consulting, Inc. (“ICE”), Uzair

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Sattar, and Derick Needham (collectively, “Plaintiffs”), and Defendant Gavin

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Jensen (“Defendant”) (collectively, the “Parties”), by and through their respective

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counsel, hereby enter into this Stipulation to Continue the Case Management

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Conference and Hearing on ICE’s Motion to Dismiss. This Stipulation is based on

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the contents of this stipulation and the Declaration of Andrew C. Crane (“Crane

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Dec.”), filed concurrently herewith.

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WHEREAS, on October 26, 2016, the Court reset the hearing date for ICE’s

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Motion to Dismiss Defendant’s Second, Third, Fourth, and Fifth Counterclaims

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(“Motion to Dismiss”) to December 1, 2016 at 1:30 p.m. (Dkt. No. 81). Per this

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same order, the Court also reset the Case Management Conference from

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November 8, 2016, to December 1, 2016. Crane Dec., ¶ 2.

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WHEREAS, on November 2, 2016, the Court reset the hearing date for

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ICE’s Motion to Dismiss and the Case Management Conference from

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December 1, 2016, to December 8, 2016, at 1:30 p.m. (Dkt. No. 84). Crane Dec.,

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¶ 3.

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WHEREAS, Andrew C. Crane, lead trial counsel for Plaintiffs, cannot

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appear on December 8, 2016, due to an all-day arbitration previously scheduled

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for that date. Crane Dec., ¶ 4.

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WHEREAS, the Parties have agreed to a one-week continuance of the

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hearing date and the Case Management Conference, from December 8 to

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December 15, 2016, at 1:30 p.m., to accommodate Mr. Crane’s conflict and ensure

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that lead trial counsel for the Plaintiffs is present at the hearing and Case

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Management Conference. Crane Dec., ¶ 5.

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WHEREAS, if the Court is inclined to grant this Stipulation, the Parties
request that the time of the hearing and Case Management Conference remain at

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Case No. 3:16-cv-04349-EMC

STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND HEARING ON
ICE CONSULTING, INC.’S MOTION TO DISMISS AND [PROPOSED] ORDER
31336711.v1

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1:30 p.m. on December 15, 2016, due to a conflict for Mr. Singh, lead trial

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counsel for Defendant, during the morning of December 15. Crane Dec., ¶ 5.

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WHEREAS, the extension sought by this Stipulation will only marginally

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affect the schedule for this case by continuing the hearing and Case Management

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Conference by one week. This would not affect any other dates currently

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calendared, and as of the filing of this Stipulation, there are no dates currently

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calendared beyond the hearing and Case Management Conference. Crane Dec., ¶

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6.

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THEREFORE, THE PARTIES HEREBY STIPULATE:

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That the hearing on ICE’s Motion to Dismiss and the Case Management

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Conference shall be continued from December 8, 2016, to December 15, 2016, at

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1:30 p.m.

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IT IS SO STIPULATED.

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Date:

November 10, 2016

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NOSSAMAN LLP
VERONICA M. GRAY
ANDREW C. CRANE
By: /s/ Andrew C. Crane
Andrew C. Crane

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Attorneys for Plaintiffs and CounterDefendants
ICE Consulting, Inc.; Uzair Sattar;
and Derick Needham

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November 10, 2016

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DHILLON LAW GROUP INC
By: /s/ Nitoj P. Singh
Nitoj P. Singh

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Attorneys for Defendant and CounterClaimant
Gavin Jensen

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Case No. 3:16-cv-04349-EMC

STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND HEARING ON
ICE CONSULTING, INC.’S MOTION TO DISMISS AND [PROPOSED] ORDER
31336711.v1

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ORDER

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PURSUANT TO THE STIPULATION AND GOOD CAUSE APPEARING,

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IT IS SO ORDERED that the Motion to Dismiss and the Case Management

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Conference be continued to December 15, 2016 at 1:30 P.M. in Department 5.

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Hon. Edward ED Chen
RDER M.
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Case No. 3:16-cv-04349-EMC

STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND HEARING ON
ICE CONSULTING, INC.’S MOTION TO DISMISS AND [PROPOSED] ORDER
31336711.v1