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

Filing 307

STIPULATION AND ORDER to Certain Pretrial Deadlines re 302 . Signed by Judge Jeremy Fogel on 7/2/09. (dlm, COURT STAFF) (Filed on 7/6/2009)

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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] Michelle C. Lee (State Bar No. 244836) [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 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\646468.1 STIPULATION TO CERTAIN PRETRIAL DEADLINES; [PROPOSED] ORDER // CASE NO. C 06-03359 JF

CASE NO. C 06-03359 JF (Consolidated With Case No. C 06-00213 JF) STIPULATION TO CERTAIN PRETRIAL DEADLINES; ------------------- ORDER [PROPOSED]

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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 Defendants CTG International (North America) Inc. ("CTG") and Taishan Fiberglass, Inc. ("Taishan"), by and through their respective counsel of record. WHEREAS, trial is currently scheduled to commence August 21, 2009; WHEREAS, counsel for the Parties have met and conferred with respect to pretrial deadlines other than those set by the Court at pre-trial conferences on June 12, 2009 and June 26, 2009; NOW THEREFORE, THE PARTIES HEREBY AGREE AND STIPULATE, subject to Court approval, to the following additional pretrial deadlines: DEADLINE Parties shall exchange proposed joint trial exhibit lists, along with all trial exhibits not previously produced, and best quality images (in PDF or TIF format) of any proposed written trial exhibits Parties shall exchange proposed designations of deposition testimony and discovery responses Parties shall meet and confer regarding proposed joint trial exhibit lists Parties exchange proposed jury instructions, jury questionnaire, and voir dire questions Parties shall exchange objections and counterdesignations of deposition testimony and discovery responses Parties shall meet and confer regarding objections to designations of depositions and discovery responses Parties shall file joint trial exhibit list and exchange all demonstrative aids not previously produced Parties shall file proposed jury instructions Parties shall file proposed voir dire questions Parties shall file proposed jury questionnaire
597\646468.1

DATE July 13, 2009

July 14, 2009 July 20, 2009 July 21, 2009 July 23, 2009

July 27, 2009

July 27, 2009

July 29, 2009 July 30, 2009 July 30, 2009 -2// CASE NO. C 06-03359 JF

STIPULATION TO CERTAIN PRETRIAL DEADLINES; [PROPOSED] ORDER

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

DEADLINE Parties shall file agreed final deposition and discovery designations and any remaining objections Parties shall submit all remaining filings regarding trial exhibits and any objections to particular demonstrative aids Trial Begins IT IS SO STIPULATED. Dated: June 30, 2009

DATE July 31, 2009

July 31, 2009

August 21, 2009

HOPKINS & CARLEY A Law Corporation

By: / s / Michelle C. Lee Michelle C. Lee Attorneys for Plaintiff/Defendant/ Third-Party Plaintiff GLASFORMS, INC., a California corporation Dated: June 30, 2009 CAMPBELL, WARBURTON, FITZSIMMONS, SMITH, MENDELL & PASTORE

By:

/ s / Lisa Jeong Cummins J. Michael Fitzsimmons Lisa Jeong Cummins Attorneys for Third Party Defendant CTG INTERNATIONAL (NORTH AMERICA) INC.

/// /// /// /// /// /// /// [Signatures continue on following page]
597\646468.1

-3// CASE NO. C 06-03359 JF

STIPULATION TO CERTAIN PRETRIAL DEADLINES; [PROPOSED] ORDER

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

Dated: June 30, 2009

BAKER & DANIELS LLP

By:

/ s / Kevin M. Toner 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.

IT IS ORDERED that: The Stipulation as to Certain Pretrial Deadlines is GRANTED.

2 Dated: July _____, 2009

HONORABLE JEREMY FOGEL United States District Court Judge

597\646468.1

-4// CASE NO. C 06-03359 JF

STIPULATION TO CERTAIN PRETRIAL DEADLINES; [PROPOSED] ORDER

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

PURSUANT TO GENERAL ORDER NO. 45, I, Michelle C. Lee, the ECF User transmitting and filing this Stipulation to Certain Pretrial Deadlines and [Proposed] Order Thereon, attest that I have obtained the concurrence of Lisa Jeong Cummins and Kevin M. Toner on this filing. I declare the foregoing under the penalty of perjury.

Dated: June 30, 2009

HOPKINS & CARLEY A Law Corporation

By:

/ s / Michelle C. Lee Michelle C. Lee Attorneys for Plaintiff/Defendant/ThirdParty Plaintiff GLASFORMS, INC., a California corporation

597\646468.1 STIPULATION TO CERTAIN PRETRIAL DEADLINES; [PROPOSED] ORDER // CASE NO. C 06-03359 JF

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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 July 1, 2009, the foregoing STIPULATION TO CERTAIN PRETRIAL DEADLINES; [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 Michelle C. Lee 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\638788.1 STIPULATION TO CERTAIN PRETRIAL DEADLINES; [PROPOSED] ORDER // CASE NO. C 06-03359 JF