Dong Ah Tire & Rubber Co., Ltd v. Glasforms Inc.,

Filing 233

STIPULATION AND ORDER AS TO FURTHER BRIEFING ON GLASFORMS'S MOTION TO COMPEL RE: 232 Stipulation filed by Glasforms Inc. (rslc2, COURT STAFF) (Filed on 5/4/2009)

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HOPKINS & CARLEY
A T T O R N E Y S A T LAW SAN JOSE

William S. Klein (State Bar No. 121792) [e-mail] Robert A. Christopher (State Bar No. 89035) [e-mail] Eugene Ashley (State Bar No. 171885) [e-mail] Noelle R. Dunn (State Bar No. 226913) [e-mail] HOPKINS & CARLEY A Law Corporation The Letitia Building 70 South First Street San Jose, CA 95113-2406 mailing address: P.O. Box 1469 San Jose, CA 95109-1469 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff/Defendant/Third-Party Plaintiff GLASFORMS, INC., a California corporation

*E-Filed 5/4/09*

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION DONG AH TIRE & RUBBER CO., LTD., a Korean Corporation, Plaintiff, v. GLASFORMS, INC., a California Corporation, Plaintiff/Defendant/ Third-Party Plaintiff. v. CTG INTERNATIONAL (NORTH AMERICA) INC., an Indiana Corporation; TAISHAN FIBERGLASS, INC., a corporation organized under the laws of the People's Republic of China, Defendants/Third-Party Defendants.
597\636280.1 STIPULATION AS TO FURTHER BRIEFING ON GLASFORMS' MOTION TO COMPEL; [PROPOSED] ORDER C 06-03359 JF

CASE NO. C 06-03359 JF (Consolidated With Case No. C 06-00213 JF) STIPULATION AS TO FURTHER BRIEFING ON GLASFORMS' MOTION TO COMPEL; [PROPOSED] ORDER

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HOPKINS & CARLEY
A T T O R N E Y S A T LAW SAN JOSE

This stipulation is entered into between Plaintiff/Defendant/Third-Party Plaintiff Glasforms, Inc. ("Glasforms") and Third-Party Defendant Taishan Fiberglass, Inc. ("Taishan"), by and through their respective counsel of record. RECITALS WHEREAS, Glasforms and Taishan (collectively the "Parties") executed and filed a stipulation to reschedule further briefing on Glasforms' Motion to Compel Further Responses by Taishan to Request for Production of Documents and Things, Sets Four and Five ("Motion to Compel") on April 9, 2009; WHEREAS, the Court on April 10, 2009 issued an order, based on the Parties' stipulation, that required supplemental briefs regarding Glasforms' Motion to Compel to be filed by each party, jointly or separately, by May 1, 2009; WHEREAS, as directed by the Court, counsel for the Parties have met and conferred in good faith to resolve the issues that are the subject of the Motion to Compel; WHEREAS, on April 8, 2009, Taishan produced several Chinese language documents pursuant to the Parties' meet and confer efforts; WHEREAS, Glasforms has translated these recently-produced documents, and seeks additional information about them from Taishan; WHEREAS, the Parties believe that additional time may allow them to reach a mutually satisfactory arrangement as to the remaining request for production; NOW THEREFORE, THE PARTIES HEREBY AGREE AND STIPULATE, subject to Court approval, that the time within which Supplemental brief(s) regarding Glasforms' Motion to /// /// /// /// /// /// ///
597\636280.1

-2C 06-03359 JF

STIPULATION AS TO FURTHER BRIEFING ON GLASFORMS' MOTION TO COMPEL; [PROPOSED] ORDER

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HOPKINS & CARLEY
A T T O R N E Y S A T LAW SAN JOSE

Compel shall be filed by Glasforms and Taishan, jointly or separately, be enlarged to and including May 15, 2009. IT IS SO STIPULATED:

Dated: May __, 2009

BAKER & DANIELS LLP

By: / s / April Sellers David K. Herzog Kevin M. Toner April Sellers Jennifer M. Phelps Attorneys for Third-Party Defendants TAISHAN FIBERGLASS INC and CTG INTERNATIONAL (NORTH AMERICA) INC. Dated: May __, 2009 HOPKINS & CARLEY A Law Corporation

By: / s / Noelle R. Dunn Noelle R. Dunn Attorneys for Plaintiff/Defendant/ Third-Party Plaintiff GLASFORMS, INC., a California corporation IT IS ORDERED that: Supplemental brief(s) regarding Glasforms' Motion to Compel shall be filed by Glasforms
May 15 and Taishan, jointly or separately, by _____________, 2009.

Dated: May _____, 2009

4

HONORABLE RICHARD SEEBORG Magistrate Judge, United States District Court

597\636280.1

-3C 06-03359 JF

STIPULATION AS TO FURTHER BRIEFING ON GLASFORMS' MOTION TO COMPEL; [PROPOSED] ORDER

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HOPKINS & CARLEY
A T T O R N E Y S A T LAW SAN JOSE

CERTIFICATE OF SERVICE I certify that on May 1, 2009, the foregoing STIPULATION AS TO FURTHER BRIEFING ON GLASFORMS' MOTION TO COMPEL; [PROPOSED] ORDER was filed electronically. Notice of this filing will be sent to the following parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. William S. Klein Robert A. Christopher Eugene Ashley Noelle R. Dunn HOPKINS & CARLEY A Law Corporation 70 South First Street San Jose, CA 95113 Telephone: [phone] Attorneys for Plaintiff/Defendant/Third-Party Plaintiff GLASFORMS, INC.

/s/

Diana L. Hodges

597\636280.1 STIPULATION AS TO FURTHER BRIEFING ON GLASFORMS' MOTION TO COMPEL; [PROPOSED] ORDER C 06-03359 JF