Zynga Game Network Inc v. Bling

Filing 35

ORDER re 34 Granting Stipulated Request to Continue Fact Discovery Deadline. Signed by Judge Claudia Wilken on 8/12/2010. (ndr, COURT STAFF) (Filed on 8/12/2010)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Larry W. McFarland (Bar No. 129668) E-Mail: lmcfarland@kmwlaw.com Dennis Wilson (Bar No. 155407) E-Mail: dwilson@kmwlaw.com David K. Caplan (Bar No. 181174) E-Mail: dcaplan@kmwlaw.com Christopher Varas (Bar No. 257080) E-Mail: cvaras@kmwlaw.com KEATS McFARLAND & WILSON LLP 9720 Wilshire Boulevard Penthouse Suite Beverly Hills, California 90212 Telephone: (310) 248-3830 Facsimile: (310) 860-0363 Attorneys for Plaintiff ZYNGA GAME NETWORK INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION ZYNGA GAME NETWORK INC. Plaintiff, v. CHIRAG KENIA, A/K/A DANNY BLING, an individual; and K-VALUEMART INDIA PVT. LTD., an Indian entity,, Defendants. CASE NO. CV 09-3263 CW (EMC) STIPULATED REQUEST TO CONTINUE FACT DISCOVERY DEADLINE; and PROPOSED ORDER CASE NO. CV 09-3263 CW (EMC) STIPULATED REQUEST TO CONTINUE FACT DISCOVERY DEADLINE AND PROPOSED ORDER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -1CASE NO. CV 09-3263 CW (EMC) STIPULATED REQUEST TO CONTINUE FACT DISCOVERY DEADLINE AND PROPOSED ORDER Plaintiff Zynga Game Network Inc. ("Zynga") and defendants Chirag Kenia and KValuemart India Pvt. Ltd. ("Defendants") (Zynga and Defendants are collectively referred to as the "Parties") submit this stipulated request to continue the fact discovery deadline in this matter. WHEREAS: The Court held a Case Management Conference in this case on June 1, 2010; and WHEREAS: The Court issued a Case Management Order on June 1, 2010 (the "Order") which specifies that fact discovery in this case must be completed by September 17, 2010; and WHEREAS: The Order specifies that expert discovery must be completed by November 29, 2010; and WHREAS: Defendants have filed a motion to dismiss the First Amended Complaint for lack of personal jurisdiction (the "Motion"), which is noticed for hearing on September 30, 2010; and WHEREAS: The Parties anticipate that additional discovery may be required before the hearing on the Motion, and following the Court's ruling on the Motion; and WHEREAS: The Parties agree that the nature and status of this litigation are such that expert and fact discovery can proceed concurrently; and WHEREAS: The Parties anticipate that an extension of the fact discovery deadline from September 17 to November 29 will allow them sufficient time to complete discovery regardless of the Court's ruling on the Motion; and WHEREAS: An extension of the fact discovery deadline to November 29 will not postpone any of the other dates in the Order; and WHEREAS: The Parties submit this stipulation to this Court rather than to Magistrate Chen because it requests a modification of this Court's Order. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 THEREFORE, the Parties stipulate and respectfully request that the Court modify the Case Management Order by continuing the deadline for completion of fact discovery from September 17, 2010 to November 29, 2010. IT IS SO STIPULATED KEATS McFARLAND & WILSON LLP Dated: August 6, 2010 By: /s/ Christopher T. Varas Attorneys for Plaintiff ZYNGA GAME NETWORK INC. STRASSBURG, GILMORE & WEI LLP Dated: August 6, 2010 By: /s/ William Gilmore Attorneys for Defendants CHIRAG KENIA and K-VALUEMART INDIA PVT. LTD. PURSUANT TO STIPULATION, IT IS SO ORDERED. The deadline for completion of fact discovery in this case is continued until November 29, 2010. All other dates in the Court's Case Management Order remain unchanged. ENTERED THIS 12th DAY OF August, 2010 _____________________________________ The Honorable Claudia Wilken, United States District Judge -2- CASE NO. CV 09-3263 CW (EMC) STIPULATED REQUEST TO CONTINUE FACT DISCOVERY DEADLINE AND PROPOSED ORDER

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