Ontel Products Corporation v. Bejing Dunhuang Heguang Information Technology Co. Ltd et al

Filing 12

STIPULATION AND ORDER TO EXTEND CASE MANAGEMENT DATES re 11 Stipulation filed by Ontel Products Corporation. Joint Case Management Statement due by 7/22/2010. Initial Case Management Conference set for 7/29/2010 02:00 PM. Signed by Judge Phyllis J. Hamilton on 5/4/10. (nah, COURT STAFF) (Filed on 5/4/2010)

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MOUNT & STOELKER, P.C. RIVERPARK TOWER, SUITE 1650 333 WEST SAN CARLOS STREET SAN JOSE, CALIFORNIA 95110-2740 TELEPHONE [phone]

Daniel S. Mount, Esq. (Cal. Bar No. 77517) Daniel H. Fingerman, Esq. (Cal. Bar No. 229683) Mount & Stoelker, P.C. RiverPark Tower, Suite 1650 333 West San Carlos Street San Jose CA 95110-2740 Phone: [phone] Fax: [phone] Email: [e-mail], [e-mail] Jason M. Drangel, Esq. (admitted pro hac vice) Epstein Drangel Bazerman & James, LLP 60 East 42nd St Ste 820 New York NY 10165 Phone: [phone] Fax: [phone] Email: [e-mail] Attorneys for Ontel Products Corporation United States District Court Northern District of California Ontel Products Corporation Plaintiff vs. Beijing Dunhuang Heguang Information Technology Co. Ltd.; Mei Fu Luo; and United Logistics Solutions Inc. Defendants ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 4:10-00386-PJH U.S. Judge Phyllis J. Hamilton Stipulation To Extend Case Management Dates and [Proposed] Order

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MOUNT & STOELKER, P.C. RIVERPARK TOWER, SUITE 1650 333 WEST SAN CARLOS STREET SAN JOSE, CALIFORNIA 95110-2740 TELEPHONE [phone]

Plaintiff Ontel products Corporation and Defendants Beijing Dunhuang Heguang Information Technology Co. Ltd.; Mei Fu Luo; and United Logistic Solutions Inc. stipulate as follows: 1. Defendants Mei Fu Luo; and United Logistic Solutions Inc. were served on February

6, 2010 and February 8, 2010, respectively. 2. served. 3. All parties have reached an agreement in principle to settle this case and are working Defendant Beijing Dunhuang Heguang Information Technology Co. Ltd. was not yet

to prepare a formal settlement agreement and a stipulated dismissal. 4. Plaintiff has informally extended the defendants (except Beijing Dunhang who has

still not been served) time to answer the complaint, so that the parties could discuss settlement. 5. All parties now request an extension of the case management dates, so that they can

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finalize the settlement agreement and the stipulated judgment without incurring the extra costs associated with counsel preparing a joint case management report and attending the case management conference. The parties still intend to resolve this case by their settlement agreement and stipulated dismissal by June 30, 2010. The parties believe they can do so, which would avoid the need for a case management conference. 6. The present case management deadlines, were set by the court's initial scheduling

order on March 9, 2010: a. May 6, 2010: Last day to file Rule 26(f) Report, complete initial disclosures or state objection in Rule 26(f) Report and file Case Management Statement per attached Standing Order re Contents of Joint Case Management Statement b. 7. May 13, 2010: INITIAL CASE MANAGEMENT CONFERENCE (CMC).

The parties request that the case management deadlines be extended as follows: a. July 22, 2010: Last day to file Rule 26(f) Report, complete initial disclosures or state objection in Rule 26(f) Report and file Case Management Statement per attached Standing Order re Contents of Joint Case Management Statement. b. July 29, 2010: INITIAL CASE MANAGEMENT CONFERENCE (CMC).

Page 1 Stipulation To Extend Case Management Dates and [Proposed] Order

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MOUNT & STOELKER, P.C. RIVERPARK TOWER, SUITE 1650 333 WEST SAN CARLOS STREET SAN JOSE, CALIFORNIA 95110-2740 TELEPHONE [phone]

It is so stipulated: Date: April 30, 2010 Mount & Stoelker, P.C., /s/ Dan Fingerman Attorneys for Plaintiff Ontel Products Corporation /s/ Bart Selden _____________________________ Attorneys for Defendant United Logistic Solutions, Inc. /s/ James Cai ______________________________ Attorneys for Defendant Mei Fu Luo

Date: April 30, 2010

Date: April 30, 2010

As the attorney electronically filing this document, I attest that my co-counsel, Jason Drangel, informs me that Bart Selden, James Cai and Frances Bivens (counsel for Beijing Dunhang) have concurred in this filing. Date: April 30, 2010 Mount & Stoelker, P.C., /s/ Dan Fingerman Attorneys for Plaintiff Ontel Products Corporation

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Pursuant to stipulation, IT IS SO ORDERED. 16 17 18 19 20 21 22 23 24 25 26 27 28
Page 2 Stipulation To Extend Case Management Dates and [Proposed] Order
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