Meta Company v. Zhong et al

Filing 57

STIPULATION AND ORDER re 56 TO CONTINUE THE CASE MANAGEMENT CONFERENCE AND TO EXTEND ADR DEADLINES filed by Meta Company Case Management Statement due by 10/19/2017. Initial Case Management Conference set for 10/26/2017 01:30 PM in Courtroom 5, 17th Floor, San Francisco. Signed by Judge Edward M. Chen on 8/31/17. (bpfS, COURT STAFF) (Filed on 8/31/2017)

1 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
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A Limited Liability Partnership
Including Professional Corporations
JENNIFER G. REDMOND, Cal. Bar No. 144790
[e-mail]
PAUL S. COWIE, Cal. Bar No. 250131
[e-mail]
JOHN-PAUL S. DEOL, Cal. Bar No. 284893
[e-mail]
Four Embarcadero Center, 17th Floor
San Francisco, CA 94111-4109
Telephone:
415.434.9100
Facsimile:
415.434.3947

9 Attorneys for Plaintiff
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META COMPANY

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

14 META COMPANY, a Delaware corporation,

Case No. 3:17-cv-03259-EMC

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STIPULATED REQUEST AND
[PROPOSED] ORDER TO CONTINUE
THE CASE MANAGEMENT
CONFERENCE AND TO EXTEND ADR
DEADLINES

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Plaintiff,
v.

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ZHANGYI ZHONG (a.k.a. Zhangyi “Johnny”
18 Zhong, a.k.a. Zhangyi “Kevin” Zhong), an
individual, DREAMWORLD USA INC., a
19 Delaware corporation, and DOES 1 through
20 20.
Defendants.

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Case No. 3:17-cv-03259-EMC
SMRH:483913797.1

STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE CASE
MANAGEMENT CONFERENCE AND TO EXTEND ADR DEADLINES

Pursuant to Local Rule 6-2 of the Northern District of California, Defendants Zhangyi Zhong

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2 and Dreamworld USA Inc. (“Defendants”) and Plaintiff Meta Company (“Meta” or “Plaintiff”)
3 hereby make this stipulated request that the Court continue the case management conference
4 currently scheduled for September 14, 2017, as well as extend the deadlines for the Parties to file
5 the ADR Certification and Stipulation to ADR Process/Notice of Need for ADR Phone Conference.
WHEREAS, the Parties have tentatively resolved the above-captioned lawsuit (Deol Decl.,

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7 ¶ 2);

WHEREAS, the Parties wish to avoid burdening the Court with a case management

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9 conference while they are still working out the details of the tentative settlement (Deol Decl., ¶ 3);
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WHEREAS a case management conference is currently scheduled for September 14, 2017;

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WHEREAS a joint case management conference statement is due by September 7, 2017;

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WHEREAS, the deadline to have filed the ADR Certification and Stipulation to ADR

13 Process/Notice of Need for ADR Phone Conference was August 17, 2017;
WHEREAS, there have been three previous extensions of time while the Parties have

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15 endeavored to settle this matter (Deol Decl., ¶ 4);
WHEREAS, counsel for both Parties agree that the requested extension should not affect

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17 any other deadlines in this case (Deol Decl., ¶ 5); and
WHEREAS, Civil Local Rule 6-2(a) of the Northern District of California states, “The

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19 parties may file a stipulation … requesting an order changing time that would affect the date of an
20 event or deadline already fixed by Court order, or that would accelerate or extend time frames set
21 in the Local Rules or in the Federal Rules.”
NOW, THEREFORE, in consideration of the foregoing, the Parties hereby stipulate and

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23 request that:
(1)

the September 14, 2017 case management conference be continued to October 26,

(2)

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the Parties be allowed to file their joint case management conference statement by

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27 October 19, 2017; and
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SMRH:483913797.1

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Case No. 3:17-cv-03259-EMC

STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE CASE
MANAGEMENT CONFERENCE AND TO EXTEND ADR DEADLINES

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(3)

the Parties be allowed to file the ADR Certification and Stipulation to ADR

2 Process/Notice of Need for ADR Phone Conference by October 5, 2017.
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IT IS SO STIPULATED.

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6 Dated: August 29, 2017

Respectfully submitted,

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/s/ Rick C. Chang

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Rick C. Chang (SBN 209515)
[e-mail]
Duane H. Mathiowetz (SBN 111831)
[e-mail]
FOLEY & LARDNER LLP
555 California Street, #1700
San Francisco, CA 94104

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Counsel for Zhangyi Zhong and
Dreamworld USA Inc.

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/s/ John-Paul S. Deol

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Jennifer G. Redmond (SBN 144790)
[e-mail]
Paul S. Cowie (SBN 250131)
[e-mail]
John-Paul S. Deol (SBN 284893)
[e-mail]
SHEPPARD, MULLIN, RICHTER &
HAMPTON LLP
Four Embarcadero Center, 17th Floor
San Francisco, CA 94111-4109

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Counsel for Meta Company

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SMRH:483913797.1

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Case No. 3:17-cv-03259-EMC

STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE CASE
MANAGEMENT CONFERENCE AND TO EXTEND ADR DEADLINES

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[PROPOSED] ORDER

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3 PURSUANT TO THE PARTIES’ STIPULATION, IT IS SO ORDERED.
be filed by 10/19/17.

dward
Judge E

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______________________________________
Hon. Edward M. Chen DERED
R
U.S. District S SO O
IT I Judge

UNIT
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8/31/17
Dated: ______________
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S DISTRICT
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CMC reset for 10/26/17 at 1:30 p.m. A joint CMC Statement shall

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SMRH:483913797.1

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Case No. 3:17-cv-03259-EMC

STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE CASE
MANAGEMENT CONFERENCE AND TO EXTEND ADR DEADLINES