Golden Gate Technology, Inc. v. Magma Design Automation, Inc.

Filing 20

STIPULATION AND ORDER re 17 STIPULATION to Change Time to File Joint Case Management Statement filed by Golden Gate Technology, Inc.Parties must file their Joint Case Management Conference Statement by February 13, 2012, rather than January 27, 2012. A Case Management Conference will be held on February 27, 2012 at 2:00pm. Signed by Judge Yvonne Gonzalez Rogers on 1/24/2012. (fs, COURT STAFF) (Filed on 1/24/2012)

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1 2 3 4 5 6 7 ANDREW D. FORTNEY (SBN 178699) SHERRIE M. FLYNN (SBN 240215) BRADLEY J. LEVANG (SBN 226922) The Law Offices of Andrew D. Fortney, Ph.D., P.C. 215 W. Fallbrook Ave., Suite 203 Fresno, CA 93711 Telephone: (559) 432-6847 Facsimile: (559) 432-6872 Email: andrew.fortney@fortneylaw.com Email: sherrie.flynn@fortneylaw.com Email: bradley.levang@fortneylaw.com 8 9 10 Attorneys for Plaintiff GOLDEN GATE TECHNOLOGY, INC. 18 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ) Case No.: 3:11-cv-04862-YGR GOLDEN GATE TECHNOLOGY, INC., a ) ) STIPULATION AND [PROPOSED] California Corporation ) ORDER TO CHANGE TIME TO FILE ) ) THE JOINT CASE MANAGEMENT ) STATEMENT Plaintiff, ) ) ) ) vs. ) ) ) 19 MAGMA DESIGN AUTOMATION, INC., a ) 20 Delaware Corporation, 11 12 13 14 15 16 17 21 Defendant 22 ) 23 24 Plaintiff Golden Gate Technology, Inc. (“Plaintiff”) and Defendant Magma Design 25 Automation, Inc. (“Defendant”) hereby agree and stipulate as follows: 26 WHEREAS, Plaintiff served Defendant with the Summons and Complaint on or about 27 November 28, 2011; 28 // // 1 2 WHEREAS, this case was reassigned to the Honorable Richard Seeborg on December 3 4 5 16, 2011 (ECF No. 11) and the Court scheduled the Case Management Conference for February 23, 2012 (ECF No. 12); WHEREAS, Defendant’s response to the Complaint is presently set for February 1, 6 7 2012; WHEREAS, there have been two previous stipulations for extensions of time for 8 9 Defendant to respond to the Complaint (ECF Nos. 13 and 15); WHEREAS, pursuant to the Reassignment Order (ECF No. 16), this case was 10 11 transferred to the Honorable Yvonne Gonzalez Rogers on January 18, 2012; WHEREAS, pursuant to the Reassignment Order, all case management dates are 12 vacated and to be reset by the Court (Reassignment Order, sec. A, ¶ 6); 13 WHEREAS, the Reassignment Order further ordered the filing of a Joint Case 14 Management Conference Statement by January 27, 2012 (Reassignment Order, sec. B); 15 WHEREAS, prior to the Reassignment Order, the Joint Case Management Conference 16 Statement was due by February 16, 2012; 17 WHEREAS, prior to learning of the Reassignment Order, the parties scheduled an in18 person settlement discussion for January 27, 2012, and intend to conduct a good-faith 19 settlement discussion on that date; 20 WHEREAS, no trial date has yet been set in this action; 21 WHEREAS, the parties agree that rescheduling the due date for the Joint Case 22 23 24 Management Conference Statement to a date after the filing of Defendant’s response and the settlement discussions would allow for a more substantive Joint Case Management Conference Statement; 25 26 27 28 WHEREAS, the parties agree that rescheduling the Joint Case Management Conference Statement would lead to a more efficient use of judicial resources and orderly management and scheduling of the case; and // // Stipulation and [Proposed] Order to Change Time to File the Joint Case Management Statement Case No. 3:11-cv-04862-YGR 2 1 2 WHEREAS, the parties agree that the last day to file the Joint Case Management 3 4 5 Conference Statement shall be the later of February 16, 2012, or fourteen days prior to the date of the Case Management Conference, which is to be set by the Court. IT IS HEREBY STIPULATED that pursuant to Civil Local Rule 6-2 and the 6 7 8 9 10 Declaration of Bradley J. Levang that the last day to file the Joint Case Management Conference Statement shall be the later of February 16, 2012, or fourteen days prior to the date of the Case Management Conference, which is to be set by the Court. Date: _January 20, 2012_____________ 11 Respectfully Submitted, O’MELVENY & MEYERS LLP 12 By: _/S/ Mark E. Miller_________________ MARK E. MILLER Attorneys for Defendant MAGMA DESIGN AUTOMATION, INC. 13 14 15 16 17 18 Date: _January 20, 2012_____________ 19 Respectfully Submitted, THE LAW OFFICES OF ANDREW D. FORTNEY, Ph.D., P.C. 20 21 By: _/S/ Bradley J. Levang______________ ANDREW D. FORTNEY SHERRIE M. FLYNN BRADLEY J. LEVANG Attorneys for Plaintiff GOLDEN GATE TECHNOLOGY, INC. 22 23 24 25 26 27 Pursuant to General Order 45, § X.B, the filer hereby attests that concurrence in the filing of this document has been obtained from each of the other signatories. 28 // Stipulation and [Proposed] Order to Change Time to File the Joint Case Management Statement Case No. 3:11-cv-04862-YGR 3 1 2 3 4 5 6 // // // // [PROPOSED] ORDER 7 8 9 10 11 Pursuant to the Stipulation above, the parties must file their Joint Case Management Conference Statement by February 13, 2012, rather than January 27, 2012. A Case Management Conference will be held on February 27, 2012. IT IS SO ORDERED. 12 13 Date: January 24, 2012 14 ____________________________________ YVONNE GONZALEZ ROGERS UNITED STATES DISTRICT JUDGE 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Stipulation and [Proposed] Order to Change Time to File the Joint Case Management Statement Case No. 3:11-cv-04862-YGR 4

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