Devon Self Storage Holdings (US) LLC v. Bader Company

Filing 21

STIPULATION AND ORDER granting 20 Request for Extension of Initial Case Management and ADR Deadlines filed by Devon Self Storage Holdings (US) LLC. Initial Case Management Conference set for 8/7/2017 01:30 PM in Courtroom A, 15th Floor, San Francisco. Case Management Statement due by 7/31/2017. Last day to meet and confer re: initial disclosures, early settlement, ADR process selection and discovery plan is 7/10/2017; last day to file Rule 26(f) Report, completed initial disclosures or state objection in Rule 26(f) Report and file Case Management Statement per Standing Order re Contents of Joint Case Management Statement is 7/24/2017. Signed by Judge Sallie Kim on 5/31/2017. (afmS, COURT STAFF) (Filed on 5/31/2017)

1 Carl D. Ciochon (Bar No. 165963)
[e-mail]
2 WENDEL, ROSEN, BLACK & DEAN LLP
1111 Broadway, 24th Floor
3 Oakland, California 94607-4036
Telephone: [phone]
4 Fax: [phone]
5 Attorneys for Plaintiff
Devon Self Storage Holdings (US) LLC
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION

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Wendel, Rosen, Black & Dean LLP

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11 DEVON SELF STORAGE HOLDINGS (US)
LLC, a Delaware limited liability company,
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Plaintiff,
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vs.
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BADER COMPANY, an Indiana corporation,
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Defendant.
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Case No. 3:17-cv-01419-SK
STIPULATION AND ORDER RE
EXTENSION OF INITIAL CASE
MANAGEMENT AND ADR DEADLINES

The Hon. Sallie Kim

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014503.0006\4727559.1

STIPULATION AND ORDER
RE EXTENSION OF INITIAL CM DEADLINES

3:17-cv-01419-SK

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This Stipulation is entered into with reference to the following facts (as set forth in the

2 accompanying Declaration of Carl D. Ciochon):
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1.

Defendant Bader Company has filed a Motion to Dismiss for Lack of Subject

4 Matter Jurisdiction or Alternatively, for Transfer of Venue. Bader’s Motion to Dismiss is set for
5 hearing on June 26, 2017.
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2.

The Court’s March 15, 2017 Order Setting Initial Case Management Conference

7 and ADR Deadlines sets an Initial Case Management Conference for June 19, 2017, prior to the
8 June 26 hearing on Bader’s Motion to Dismiss.
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3.

The parties believe that it would be more efficient for both the Court and the parties

10 if the Initial Case Management Conference were continued to a date after the Court has ruled on

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12 commit to an ADR process and a discovery schedule before the Court has ruled on Bader’s
O akland, Ca lif or ni a 946 07 -4 036

Wendel, Rosen, Black & Dean LLP

11 Bader’s Motion to Dismiss. The parties further believe that it would be premature for them to

13 Motion to Dismiss, and that the meet and confer and related filing deadlines should also be
14 continued. Accordingly, the parties are respectfully requesting that the current deadlines be
15 extended by eight weeks, as set forth below.
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WHEREFORE,

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It is hereby stipulated, by and between undersigned counsel of record to extend the

18 relevant pre-trial deadlines as follows:
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July 10, 2017:
 Last day to meet and confer re: initial disclosures, early settlement, ADR process
selection, and discovery plan;

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 file ADR Certification signed by Parties and Counsel;

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 file either Stipulation to ADR Process or Notice of Need for ADR Phone

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Conference;
July 24, 2017:

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 Last day to file Rule 26(f) Report, complete initial disclosures or state objection in

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Rule 26(f) Report and file Case Management Statement per Standing Order re

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Contents of Joint Case Management Statement.

014503.0006\4727559.1

STIPULATION AND ORDER
RE EXTENSION OF INITIAL CM DEADLINES

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3:17-cv-01419-SK

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August 7, 2017 (or such other date as the Court may propose):
 Initial Case Management Conference.
I received agreement from Benjamin Riley to this Stipulation and to submitting his

4 signature on this Stipulation on May 30, 2017.
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6 DATED: May 30, 2017

WENDEL, ROSEN, BLACK & DEAN LLP

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By:

/s/ Carl D. Ciochon
Carl D. Ciochon
Attorneys for Plaintiff
Devon Self Storage Holdings (US) LLC

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BARTKO, ZANKEL, BUNZEL & MILLER

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Wendel, Rosen, Black & Dean LLP

11 DATED: May 30, 2017

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By:

/s/ Benjamin K. Riley
Benjamin K. Riley
Attorneys for Defendant
Bader Company

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17 PURSUANT TO STIPULATION, IT IS SO ORDERED.
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19 DATED: May 31, 2017
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Sallie Kim
United States Magistrate Judge

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014503.0006\4727559.1

STIPULATION AND ORDER
RE EXTENSION OF INITIAL CM DEADLINES

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3:17-cv-01419-SK