CLRB Hanson Industries, LLC et al v. Google Inc.

Filing 195

STIPULATION and [Proposed] Order Continuing Case Management Conference by CLRB Hanson Industries, LLC, Howard Stern, Google Inc.. (Jhang, Christopher) (Filed on 9/5/2007)

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CLRB Hanson Industries, LLC et al v. Google Inc. Doc. 195 Case 5:05-cv-03649-JW Document 195 Filed 09/05/2007 Page 1 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 DAVID T. BIDERMAN, Bar No. 101577 dbiderman@perkinscoie.com JUDITH B. GITTERMAN, Bar No. 115661 jgitterman@perkinscoie.com M. CHRISTOPHER JHANG, Bar No. 211463 cjhang@perkinscoie.com PERKINS COIE LLP Four Embarcadero Center, Suite 2400 San Francisco, CA 94111 Telephone: (415) 344-7000 Facsimile: (415) 344-7288 Attorneys for Defendant Google Inc. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION CLRB HANSON INDUSTRIES, LLC d/b/a INDUSTRIAL PRINTING, and HOWARD STERN, on behalf of themselves and all others similarly situated, Plaintiffs, CASE NO. C O5-03649 JW STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE 15 v. 16 GOOGLE, INC., 17 Defendant. 18 19 20 21 22 23 24 25 26 27 28 WHEREAS, on August 21, 2007, the Court entered an Order Denying Plaintiffs' Motion For Partial Summary Judgment; Granting In Part And Denying In Part Defendant's Motion For Summary Judgment ("August 21, 2007 Order"), and therein ordered that the parties "appear for a Case Management Conference on September 17, 2007, at 10 AM" and "meet and confer and file a joint case management statement no later than ten (10) days before the date of the conference"; WHEREAS, the parties have conferred and agreed to enter into private mediation, and further agree that judicial economy would best be served by continuing the September 17, 2007 Case Management Conference, and the associated deadline to file a joint case management statement; and STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE [41063-0023/13530018_1.DOC] Dockets.Justia.com Case 5:05-cv-03649-JW Document 195 Filed 09/05/2007 Page 2 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 WHEREAS, all previous time modifications in the case are as follows: · On or about September 15, 2005, the parties filed a stipulation to extend the time for defendant Google Inc. ("Google Inc.") to respond to the Complaint by 30 days; · On November 22, 2005, the parties filed a stipulation for extension of time for Google Inc. to respond to the First Amended Complaint; · On January 5, 2006, the Court ordered, pursuant to the parties' stipulation, that the parties' joint case management statement deadline be continued to April 21, 2006, and the initial case management conference be set for May 1, 2006; · On January 31, 2006, the Court, on its own motion, continued the hearing date for Google Inc.'s Motion to Dismiss to March 13, 2006; · On February 21, 2006, the Court ordered, pursuant to the parties' stipulation, that the hearing date for Google Inc.'s Motion to Dismiss be continued to April 3, 2006, the deadline to file the joint case management statement be advanced to March 24, 2006, and that the case management conference be advanced to April 3, 2006; · On August 1, 2006, the Court ordered, pursuant to Google Inc.'s Motion to Enlarge Time and Clarify Court Order, that the deadline for Google Inc. to depose plaintiffs CLRB Hanson Industries, LLC, d/b/a Industrial Printing, and Howard Stern ("Plaintiffs") is extended to August 17, 2006; · On August 16, 2006, the Court ordered, pursuant to Plaintiffs' Motion to Enlarge Time, that the hearing for the motion for partial summary judgment be continued to November 6, 2006; · On March 15, 2007, the Court ordered, pursuant to the parties' joint request, that the hearing on Plaintiffs' Motion for Partial Summary Judgment and Google Inc.'s Motion for Summary Judgment be continued to June 11, 2007; and · On June 5, 2007, the Court ordered, on its own motion, that the hearing on the parties' summary judgment motions be continued to June 21, 2007. -2STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE [41063-0023/13530018_1.DOC] Case 5:05-cv-03649-JW Document 195 Filed 09/05/2007 Page 3 of 3 1 2 3 4 5 6 THE PARTIES THEREFORE STIPULATE and respectfully request that the Court continue the presently set September 17, 2007 Case Management Conference to December 3, 2007, at 10:00 a.m., or as soon thereafter as the Court's schedule will allow, and that the associated deadline to file a joint case management statement be continued accordingly. DATED: September 5, 2007 PERKINS COIE LLP By /S/ M. Christopher Jhang Attorneys for Defendant, Google Inc. 7 8 9 10 By 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DATED: _____________, 2007 DATED: September 5, 2007 AUDET & PARTNERS LLP /S/ Joshua C. Ezrin Attorneys for Plaintiffs CLRB Hanson Industries, LLC, dba Industrial Printing, and Howard Stern and the Proposed Class ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED. _______________________________ Honorable James Ware United States District Court Judge -3STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE [41063-0023/13530018_1.DOC]

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