Foresee Results, Inc. et al v. Auryc, Inc. et al

Filing 56

STIPULATION AND ORDER RE 55 EXTENDING DEADLINE FOR EARLY NEUTRAL EVALUATION. Case Management Statement due by 9/13/2018. Further Case Management Conference previously set for 7/12/2018 has been continued to 9/20/2018 at 10:00 AM in San Francisco, Courtroom 03, 17th Floor. Signed by Judge Richard Seeborg on 5/11/18. (cl, COURT STAFF) (Filed on 5/11/2018)

1 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
A Limited Liability Partnership
2
Including Professional Corporations
JAMES M. CHADWICK, Cal. Bar No. 157114
3 JESSE A. SALEN, Cal. Bar No. 292043
379 Lytton Avenue
4 Palo Alto, California 94301-1479
Telephone:
650.815.2600
5 Facsimile:
650.815.2601
E mail: [e-mail]
6
[e-mail]
7 Attorneys for Defendants and Counterclaimants
AURYC, INC., JINLIN WANG, FENG SHAO, and
8 AMOD SETLUR
9
UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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FORESEE RESULTS, INC. a Delaware
13 Corporation; ANSWERS CORPORATION, a
Delaware Corporation,
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Plaintiffs and Counterclaim Defendants,
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v.
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AURYC, INC., a Delaware Corporation, also
17 known as AURYC, LLC; JINLIN WANG, an
individual; FENG SHAO, an individual;
18 AMOD SETLUR, an individual; DOES 1
through 20, inclusive;
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Defendants and Counterclaimants.
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Case No. 3:17-cv-06973-RS
STIPULATION AND [PROPOSED]
ORDER EXTENDING DEADLINE FOR
EARLY NEUTRAL EVALUATION
The Hon. Richard Seeborg
United States District Judge

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SMRH:486299657.2

Civil Action No. 3:17-CV-06973-RS
STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINE FOR ENE

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Defendants and Counterclaimants AURYC, INC., JINLIN WANG, FENG SHAO, AND

2 AMOD SETLUR (collectively “Defendants”) and Plaintiffs and Counterclaim Defendants
3 FORESEE RESULTS, INC., and ANSWERS CORPORATION (collectively “Plaintiffs,” and
4 together with Defendants the “Parties”) file this joint stipulation respectfully requesting an Order
5 extending the deadline for Early Neutral Evaluation.
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WHEREAS, the Parties have agreed to engage in Early Neutral Evaluation;

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WHEREAS, the Court’s Case Management Order of March 8, 2018 provides that “[t]he

8 parties are hereby REFERRED to the court’s ADR department for the Early Neutral Evaluation to
9 take place, ideally, within the next 90 days,” which requires the parties to engage in Early Neutral
10 Evaluation by June 6, 2018
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WHEREAS, the Parties have selected a neutral to conduct the Early Neutral Evaluation,

12 Mr. Michael Barclay, and the Early Neutral Evaluation is presently set for June 5, 2018;
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WHEREAS, the Parties agree that additional time is required in order to permit the Parties

14 to prepare for and conduct a useful Early Neutral Evaluation, and in particular to permit the Parties
15 to complete the discovery and expert analysis needed for a productive Early Neutral Evaluation;
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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by and between the

17 Parties, through their respective attorneys of record, and subject to approval by the Court, as
18 follows:
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1.

The deadline for Early Neutral Evaluation should and shall be extended by not less

20 than 60 days or more than 90 days, to a date on which the Parties and the neutral are all available,
21 to be established by the neutral. The Parties will notify the Court and the ADR Unit promptly of
22 the new date for the Early Neutral Evaluation
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2.

The Further Case Management Conference current set for July 12, 2018, shall be

24 continued to a date of the Court’s choosing after September 14, 2018. The parties shall file a Joint
25 Case Management Statement at least one week prior to the Conference.
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SMRH:486299657.2

Civil Action No. 3:17-CV-06973-RS
-1STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINE FOR ENE

1 Dated: May 11, 2018

SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

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By

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/s/ James M. Chadwick
JAMES M. CHADWICK
JESSE A. SALEN
Attorneys for Defendants and Counterclaimants
AURYC, INC., JINLIN WANG, FENG SHAO,
and AMOD SETLUR

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7

Dated: May 11, 2018

Respectfully submitted,

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HOWARD & HOWARD ATTORNEYS PLLC
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By

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/s/ Andrew M. Grove
PATRICK M. MCCARTHY
ANDREW M. GROVE
RYAN A. ELLIS
Attorneys for Plaintiffs and Counterclaim
Defendants FORESEE RESULTS, INC. and
ANSWERS CORPORATION

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ATTORNEYS’ E-FILING ATTESTATION

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As the attorney e-filing this document, and pursuant to Local Rule 5-1(i)(3), I hereby attest

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that counsel for Plaintiffs and Counterclaim Defendants FORESEE RESULTS, INC. and
ANSWERS CORPORATION, whose electronic signature appears above, have concurred in this
filing.
Dated: May 11, 2018

SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
By

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/s/ James M. Chadwick
JAMES M. CHADWICK
JESSE A. SALEN
Attorneys for Defendants and Counterclaimants
AURYC, INC., JINLIN WANG, FENG SHAO,
and AMOD SETLUR

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SMRH:486299657.2

Civil Action No. 3:17-CV-06973-RS
-2STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINE FOR ENE

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ORDER
The Court, having considered the stipulation of the Parties, and good cause appearing

3 therefor, it is ordered that the deadline for Early Neutral Evaluation should and shall be extended
4 in accordance with the Parties’ stipulation. The Further Case Management Conference currently
September 20, 2018
5 set for July 12, 2018, shall be continued to ___________________ at 10:00 a.m. in Courtroom 3,

6 17th Floor, United States Courthouse, 450 Golden Gate Avenue, San Francisco, California. The
7 parties shall file a Joint Case Management Statement at least one week prior to the Conference.
5/11/18
8 Dated: _____________________

9
The Honorable Richard Seeborg
United States District Judge

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Civil Action No. 3:17-CV-06973-RS
-3STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINE FOR ENE