Huatai USA LLC v. Chiang

Filing 60

STIPULATION AND ORDER EXTENDING TIME re 59 Stipulation filed by John A. Chiang. Signed by Judge Phyllis J. Hamilton on 12/20/11. (nah, COURT STAFF) (Filed on 12/20/2011)

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Richard Duane (SBN 37880)
Duane & Seltzer LLP
1936 University Ave., Suite 355
Berkeley, CA 94704
Tel: [phone]
E-mail: [e-mail]
Lizbeth Hasse (SBN 104517)
Creative Industry Law Group
155 Sansome Street, Suite 500
San Francisco, CA 94104
Tel: [phone]
E-mail: [e-mail]

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Attorneys for Defendant
John A. Chiang d/b/a/ FCB International

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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HUATAI USA, LLC,

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Case No.: 4:11-cv-01855-PJH

Plaintiff,

STIPULATION EXTENDING TIME
FOR DEFENDANT JOHN CHIANG
d/b/a “FCB INTERNATIONAL” TO
SERVE RESPONSES TO PLAINTIFF’S
FIRST SET OF INTERROGATORIES
AND DOCUMENT REQUESTS

vs.
JOHN A CHIANG d/b/a “FCB
INTERNATIONAL,”
Defendant.

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During the Case Management Conference in this matter, held November 17, 2011, all
parties agreed to exchange Initial Disclosures on or before December 19, 2011 and also to
exchange written discovery requests as soon as possible. Accordingly, Plaintiff served
HUATAI USA, LLC v. JOHN CHIANG d/b/a “FCB INTERNATIONAL”
Case No. C11-01855 PJH
STIPULATION EXTENDING TIME FOR DEFENDANT TO
SERVE DISCOVERY RESPONSES
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Defendant with its First Set of Interrogatories and Requests for Production of Documents on

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November 21, 2011 and Defendant’s responses thereto are currently due on December 21, 2011.

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However, due to medical problems with his eyesight, Defendant John A. Chiang is

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currently unable to (1) return to the United States from China prior to December 21, 2011 and/or

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(2) read documents necessary for him to provide responses to Plaintiff’s first set of written

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discovery.

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In addition, Defendant may have in his possession or may be bringing back from China
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documents that may be responsive to Plaintiff’s discovery and/or required to be disclosed under
F.R.C.P. Rule 26. Defendant reserves the right to supplement the Initial Disclosures and
documents produced on December 19, 2011.

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WHEREFORE IT IS AGREED AND STIPULATED AS FOLLOWS:

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1) All parties will exchange Initial Disclosures and documents on Monday, December

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19, 2011.
2) The deadline for Defendant’s Responses to Plaintiff’s First Set of Interrogatories and
Document Requests is hereby extended until January 4, 2012.
IT IS SO STIPULATED.
Dated: December 19, 2011

_________/s/_______________________
RICHARD DUANE
Attorney for Defendant
JOHN CHIANG d/b/a “FCB INTERNATIONAL”

Dated: December 19, 2011

_________/s/________________________
MICHAEL ONUFRAK
Attorney for Plaintiff
HUATAI USA, LLC

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HUATAI USA, LLC v. JOHN CHIANG d/b/a “FCB INTERNATIONAL”
Case No. C11-01855 PJH
STIPULATION EXTENDING TIME FOR DEFENDANT TO
SERVE DISCOVERY RESPONSES
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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

12/20/11
Dated: _______________________

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_______________________________
HON. PHYLLIS J. HAMILTON
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Judge,T IS SO ORCourt
U.S. District

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HUATAI USA, LLC v. JOHN CHIANG d/b/a “FCB INTERNATIONAL”
Case No. C11-01855 PJH
STIPULATION EXTENDING TIME FOR DEFENDANT TO
SERVE DISCOVERY RESPONSES
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