NeilMed Products, Inc. v. Techworld Corporation, Inc.

Filing 61

STIPULATION AND ORDER RESCHEDULING BRIEFING DATES FOR PLAINTIFF'S MOTION FOR LEAVE TO FILE FIRST AMENDED COMPLAINT re 59 Stipulation filed by Techworld Corporation, Inc. Signed by Judge Phyllis J. Hamilton on 8/3/11. (nah, COURT STAFF) (Filed on 8/3/2011)

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REED SMITH LLP

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Cynthia E. Kernick (PA No. 43912)
[e-mail]
Alexandria C. Samuel (PA No. 207087)
[e-mail]
Reed Smith Centre, 225 Fifth Avenue
Pittsburgh, PA 15222-2716
Telephone: [phone]
Facsimile: 412 288 3063

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MURPHY PEARSON BRADLEY & FEENEY
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REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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Aaron K. McClellan
[e-mail]
James Francis Monagle
[e-mail]
88 Kearny Street, Suite 1000
San Francisco, CA 94108
Telephone: [phone]
Facsimile: 415-393-8087
Attorneys for Defendant
TechWorld Corporation, Inc.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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NEILMED PRODUCTS, INC. dba NEILMED
PHARMACEUTICALS, INC., a California
corporation,

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Plaintiff,

Case No.: 4:10-cv-04330-PJH

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vs.
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TECHWORLD CORPORATION, INC., a
Nevada corporation, and DOES 1-10 inclusive,
Defendants.

STIPULATION AND [PROPOSED]
ORDER RESCHEDULING BRIEFING
AND HEARING DATES FOR PLAINTIFF
NEILMED PRODUCTS, INC.’S MOTION
FOR LEAVE TO FILE FIRST AMENDED
COMPLAINT

And Related Counterclaims

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STIPULATION AND ORDER GRANTING STIPULATION AND [PROPOSED]
ORDER RESCHEDULING BRIEFING AND HEARING DATES FOR PLAINTIFF NEILMED PRODUCTS, INC.’S
MOTION FOR LEAVE TO FILE FIRST AMENDED COMPLAINT

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WHEREAS on July 21, 2010, Plaintiff and Counter-Defendant NEILMED PRODUCTS,

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INC. filed a Motion For Leave To File First Amended Complaint and related pleadings (“Plaintiff’s

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motion”)(Docket Nos. 42-45);

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WHEREAS on July 22, 2011, the Court set the following deadlines for the briefing and

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hearing of Plaintiff’s motion: Responses due by August 4, 2011, Replies due by August 11, 2011

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and Hearing set for September 14, 2011 at 9:00 AM before the Hon. Phyllis J. Hamilton;

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WHEREAS on July 28, 2011 Roland Tellis, Esq. of Baron and Budd, P.C. filed a substitution

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of counsel for Plaintiff and Counter-Defendant NEILMED PRODUCTS, INC, and entered an

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appearance on August 1, 2011;

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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WHEREAS the parties have conferred through counsel and believe that in their collective

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best interests and the interests of judicial economy, the currently scheduled dates related to

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Plaintiff’s motion should be rescheduled to allow new counsel to familiarize himself with the issues

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set forth in the pending motions and for further consideration of related issues by counsel;

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THEREFORE, the parties, by and through their undersigned counsel of record, hereby agree
and stipulate to the following:

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1. Any Response in Opposition to Plaintiff’s motion will be due by August 15, 2011;

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2. Any Reply in support of Plaintiff’s motion will be due by August 26, 2011;

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3. The Hearing, currently scheduled for September 14, 2011, shall remain on calendar as

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originally scheduled, or reset for another date that is convenient for the Court.

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DATED: August 1, 2011

REED SMITH LLP
By:

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/S/ Cynthia Kernick
Cynthia E. Kernick
[e-mail]
Alexandria C. Samuel
[e-mail]
REED SMITH LLP
Reed Smith Centre,
225 Fifth Avenue
Pittsburgh, PA 15222-2716
Telephone: [phone]
Facsimile: [phone]

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STIPULATION AND ORDER GRANTING STIPULATION AND [PROPOSED]
ORDER RESCHEDULING BRIEFING AND HEARING DATES FOR PLAINTIFF NEILMED PRODUCTS, INC.’S
MOTION FOR LEAVE TO FILE FIRST AMENDED COMPLAINT

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DATED: August 1, 2011

MURPHY, PEARSON, BRADLEY & FEENEY
By: /S/ James F. Monagle
James F. Monagle
88 Kearny Street, 10th Floor
San Francisco, CA 94108
Telephone: [phone]
Facsimile: 415-393-8087
Email: [e-mail]

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Attorneys for Defendant
TechWorld Corporation, Inc.

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DATED: August 1, 2011

By: /S/ Roland Tellis
Roland Tellis
BARON & BUDD, P.C.
[e-mail]
1999 Avenue of the Stars
Ste. 3450
Los Angeles, CA 90067
Telephone: [phone]
Facsimile: [phone]

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Attorney for Plaintiff & Counter-Defendant
Neilmed Products, Inc

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[PROPOSED] ORDER
Based on the above stipulation of the Parties and good cause appearing therefor,

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IT IS SO ORDERED.

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Dated: August _____, 2011

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Judge P

Hamilto

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hyllis J.

NO

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_______________________________________
ERED
Hon. Phyllis J. IT IS SO ORD
Hamilton
United States District Court n
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REED SMITH LLP

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A limited liability partnership formed in the State of Delaware

BARON & BUDD, P.C.

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F
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STIPULATION AND ORDER GRANTING STIPULATION AND [PROPOSED]
ORDER RESCHEDULING BRIEFING AND HEARING DATES FOR PLAINTIFF NEILMED PRODUCTS, INC.’S
MOTION FOR LEAVE TO FILE FIRST AMENDED COMPLAINT