Mitsui O.S.K. Lines Ltd. v. Shine International Transportation (ShenZhen) Limited

Filing 24

STIPULATION AND ORDER re 23 STIPULATION WITH PROPOSED ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE filed by Mitsui O.S.K. Lines Ltd. Case Management Conference set for 3/29/2016 01:30 PM. Deadline to respond to Amended Complaint is 2/5/16.. Signed by Magistrate Judge Kandis A. Westmore on 1/15/16. (sisS, COURT STAFF) (Filed on 1/15/2016)

Case 4:15-cv-03343-KAW Document 23 Filed 01/14/16 Page 1 of 3

1 CONTE C. CICALA, State Bar No. 173554
[e-mail]
2 CLYDE & CO US LLP
101 Second Street, 24th Floor
3 San Francisco, California 94105
Telephone: [phone]
4 Facsimile: [phone]
5 Attorneys for Plaintiff
MITSUI O.S.K. LINES, LTD.
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

11 MITSUI O.S.K. LINES, LTD.,

Case No. 4:15-cv-03343-KAW

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STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE;
[PROPOSED] ORDER

Plaintiff,

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v.

14 SHINE INTERNATIONAL
TRANSPORTATION (SHENZHEN)
15 LIMITED, R.T. EXPRESS
INTERNATIONAL, INC., TROY
16 CONTAINER LINE, LTD. and DOES
THREE THROUGH TWENTY,
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Defendants.
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WHEREAS, pursuant to stipulation, the default of Defendant Shine International

21 Transportation (Shenzhen) Limited ("Shine") was set aside on November 30, 2015. On
22 December 1, 2015, MOL filed an amended complaint that added two additional defendants. MOL
23 served the amended complaint on Shine on December 1, 2015, and is in the process of serving the
24 two newly-added defendants; and,
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WHEREAS, since December, MOL and Shine have been engaged in informal document
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exchanges and settlement discussions and would like to continue this process for as long as it
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remains productive; and,
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1971234

Case No. 4:15-cv-03343-KAW
STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER

Case 4:15-cv-03343-KAW Document 23 Filed 01/14/16 Page 2 of 3

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WHEREAS, consistent with the foregoing, MOL and Shine respectfully believe that

2 certain dates should be extended/continued accordingly.
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THEREFORE, the parties hereto do stipulated and agree and request the Court to order as

4 follows:
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1) To extend the date for Shine to respond to the Amended Complaint to and including

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February 5, 2016

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2) To continue the CMC scheduled for January 19, 2016 to March 29, 2016;

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Respectfully submitted,

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th

CLYDE & CO US LLP

CLYDE & CO US LLP

11
101 Second Street, 24 Floor
San Francisco, California 94105
Telephone: [phone]

10 Dated: January 14, 2016

By:

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/s/ Conte C. Cicala
Conte C. Cicala
Attorneys for Plaintiff
MITSUI O.S.K. LINES, LTD.

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Dated: January 14, 2016

GONZALEZ DEL VALLE LAW
By:

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/s/ Henry P. Gonzalez
Henry P. Gonzalez
Attorney-in-Fact
Shine International Transportation (Shenzhen)
Limited

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L.R. 5-l(i) ATTESTATION

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I, Conte C. Cicala, am the ECF user whose ID and password are being used to file the
attached Stipulation to Continue Case Management Conference; [Proposed] Order.

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In compliance with Local Rule 5-1, I hereby attest that concurrence in the filing of this
23 document has been obtained from the other signatories.
24 Dated: January 14, 2016

/s/ Conte C. Cicala
Conte C. Cicala

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1971234

Case No. 3:15-cv-03343
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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER

Case 4:15-cv-03343-KAW Document 23 Filed 01/14/16 Page 3 of 3

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[PROPOSED] ORDER

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Pursuant to stipulation, and good cause having been shown thereby, this Court hereby
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ORDERS as follows:
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1) Shine shall have a further extension to respond to the Amended Complaint to and
including February 5, 2016

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2) The Case Management Conference scheduled for January 19, 2016 is continued to
March 29, 2016, at 1:30 p.m.

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IT IS SO ORDERED.

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Dated: 1/15/16
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th

CLYDE & CO US LLP

101 Second Street, 24 Floor
San Francisco, California 94105
Telephone: [phone]

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UNITED STATES MAGISTRATE JUDGE
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1971234

Case No. 3:15-cv-03343
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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER