Shloss v. Sweeney et al

Filing 11

STIPULATION and (Proposed) Order to Extend Time to Respond to Complaint; Move Case Management Conference by Sean Sweeney, The Estate of James Joyce. (Nelson, Maria) (Filed on 9/29/2006)

Shloss v. Sweeney et al

Doc. 11

Case 5:06-cv-03718-JW

Document 11

Filed 09/29/2006

Page 1 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

Lawrence Lessig Jennifer Stisa Granick (SBN 168423) David S. Olson (SBN 231675) STANFORD LAW SCHOOL CYBERLAW CLINIC CENTER FOR INTERNET AND SOCIETY 559 Natyhan Abbott Way Stanford, California 94305-8610 Telephone: [phone] Facsimile: [phone] Robert Spoo (admitted pro hac vice) DOERNER, SAUNDERS, DANIEL & ANDERSON, L.L.P. 320 South Boston Avenue, Suite 500 Tulsa, Oklahoma 74103-3725 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff Maria K. Nelson (State Bar No. 155608) [e-mail] JONES DAY 555 South Flower Street, Fiftieth Floor Los Angeles, CA 90071-2300 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants SEAN SWEENEY, IN HIS CAPACITY AS TRUSTEE OF THE ESTATE OF JAMES JOYCE, AND THE ESTATE OF JAMES JOYCE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA CAROL LOEB SHLOSS, Plaintiff, v. SEAN SWEENEY, in his capacity as trustee of the Estate of James Joyce, and THE ESTATE OF JAMES JOYCE, Defendants.
LAI-2261450v1

[e-mail] [e-mail]

[e-mail]

Case No. C 06 3718 JW HRL STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT; MOVE CASE MANAGEMENT CONFERENCE Current CMC Date: Oct. 23, 2006 Requested CMC Date: Nov. 20, 2006
Joint Request to Extend Time to Respond to Complaint, Move CMC C 06 3718 JW HRL
Dockets.Justia.com

Case 5:06-cv-03718-JW

Document 11

Filed 09/29/2006

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, the Complaint in the above-captioned Civil Action was filed on June 12, 2006; WHEREAS, to date, the parties have sought and received three extensions of time for Defendants to respond to the Complaint, so that the time to respond currently is on or before September 29, 2006; and WHEREAS, the parties are engaged in settlement discussions. In order to continue such discussions and devote their resources to them, the parties agree, and respectfully request this Court to Order, a thirty day extension of the date by which the Defendants must answer, object or otherwise plead to the Complaint, up to and including October 30, 2006. The parties further request that the date of any event or deadline set by the Court in its Order Setting Initial Case Management Conference and ADR Deadlines, filed on June 12, 2006, be moved as outlined below. IT IS HEREBY STIPULATED between the parties, by and through their counsel of record, and the Court is respectfully requested to ORDER that the schedule be changed to the following: October 30, 2006: Last day for Defendants to answer, object or otherwise plead to the Complaint; 21 days before CMC: Last Day to Meet and Confer re: initial disclosures, early settlement, ADR process selection, and discovery plan; file ADR Certification signed by Parties and Counsel; and file either Stipulation to ADR Process or Notice of Need for ADR Phone Conference. 7 Days before CMC: Last day to complete initial disclosures or state objection in Rule 26(f) Report, file Case Management Statement, and file Rule 26(f) Report;

LAI-2261450v1

-1-

Joint Request to Extend Time to Respond to Complaint, Move CMC C 06 3718 JW HRL

Case 5:06-cv-03718-JW

Document 11

Filed 09/29/2006

Page 3 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

November 20, 2006, or as soon thereafter as is convenient for the Court: Initial Case Management Conference. Dated: September 29, 2006. JONES DAY By: /s/ Maria K. Nelson

Attorney for Defendants SEAN SWEENEY, IN HIS CAPACITY AS TRUSTEE OF THE ESTATE OF JAMES JOYCE, AND THE ESTATE OF JAMES JOYCE Dated: September 29, 2006 STANFORD LAW SCHOOL CYBERLAW CLINIC CENTER FOR INTERNET AND SOCIETY By /s/ David S. Olson

Attorneys for Plaintiff CAROL LOEB SHLOSS

IT IS SO ORDERED. Dated: . By

Judge, United States District Court

LAI-2261450v1

-2-

Joint Request to Extend Time to Respond to Complaint, Move CMC C 06 3718 JW HRL