IO Group, Inc. v. Veoh Networks, Inc.

Filing 64

STIPULATION and [PROPOSED] ORDER TO EXTEND DISCOVERY CUT-OFF DATES by IO Group, Inc.. (Sperlein, D.) (Filed on 4/18/2007)

IO Group, Inc. v. Veoh Networks, Inc.

Doc. 64

Case 5:06-cv-03926-HRL

Document 64

Filed 04/18/2007

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GILL SPERLEIN (172887) THE LAW FIRM OF GILL SPERLEIN 584 Castro Street, Suite 849 San Francisco, California 94114 Telephone: [phone] X32 Facsimile: [phone] [e-mail] Attorney for Plaintiff IO GROUP, INC.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. C-06-3926 (HRL) STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY CUT-OFF DATES

IO GROUP, INC., a California corporation, Plaintiff, vs. VEOH NETWORKS, Inc, a California Corporation, Defendant.

Pursuant to Civil Local Rule 6-2, Plaintiff Io Group, Inc. and Defendant Veoh Networks, Inc., hereby stipulate to extend certain discovery cutoff dates. Plaintiff requested that Defendant stipulate to an extension of time because Plaintiff believes that it needs additional discovery and that the current discovery schedule does not allow enough time. Defendant has agreed to a thirty-day extension of currently scheduled deadlines as set forth below. Although this case was originally filed on June 6, 2006, there was a dormant period during which the Court considered Plaintiff's Motion to Relate the matter to two later-filed cases. Upon

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Dockets.Justia.com

Case 5:06-cv-03926-HRL

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ordering the matters related, the Court significantly postponed the initial case management conference in order that it be held in conjunction with the later-filed, related cases. Previously, stipulations and orders resulted in the following time modifications. On August 10, 2006 the parties stipulated and the Court ordered that Defendant have until September 25, 2006 to file a pleading responsive to the Complaint and that the initial Case Management Conference set for September 26, 2006 be reset for October 17, 2006. On September 13, 2006, the parties stipulated and the Court subsequently ordered that Defendant's Response to Plaintiff's Motion to Relate would be due on September 25, 2006. On September 21, 2006 the parties stipulated and the Court subsequently ordered that the Court not rule on Plaintiff's Motion to Relate until October 19, 2006 so that all parties had sufficient time to respond. The Stipulation and Order also took the Case Management Conference off calendar until after the Court ruled on the Motion to Relate. Upon ordering the cases related on October 25, 2006, the Court set the Initial Case Management Conference for all related cases for December 5, 2006. Subsequently, Defense requested, Plaintiff stipulated, and the Court ordered, that the date for exchanging initial disclosures be extended from the Court's original December 15, 2006 deadline to January 16, 2007. This stipulation and proposed order if issued, would effect the discovery dates set by the Court at the December 5, 2006 Case Management Conference. Moreover, other dates such as the deadline for hearing dispositive motions may also need to be extended. WHEREAS the Court previously set April 30, 2007 as the deadline for fact discovery; WHEREAS the Court previously set June 22, 2007 as the deadline for expert discovery; WHEREAS the Court indicated at the Case Management Conference that extensions would be granted if reasonably necessary.

The parties do therefore stipulate and agree as follows: 1. 2. 3. To extend fact discovery cutoff until May 30, 2007; To extend the Designation of Experts deadline until June 8, 2007; To Extend the Designation of Rebuttal Experts until June 22, 2007;
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4. 5.

To extend expert discovery cutoff until July 22, 2007; and That the Court recalendar any other dates as appropriate.

SO STIPULATED.

Dated: 4/18/2007

/s/ Gill Sperlein Gill Sperlein THE LAW FIRM OF GILL SPERLEIN Attorney's for Plaintiff

Dated: 4/18/2007

/s/ Jennifer A. Golinveaux Jennifer A. Golinveaux WINSTON & STRAWN, LLP Attorney's for Defendant

I hereby attest that concurrence in the filing of the document has been obtained from each of the other signatories.

Dated: 4/18/2007

/s/ Gill Sperlein Gill Sperlein THE LAW FIRM OF GILL SPERLEIN Attorney's for Plaintiff

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C-06-3926 (HRL)

Case 5:06-cv-03926-HRL

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[PROPOSED] ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED.

Dated: HONORABLE HOWARD R. LLOYD UNITED STATES MAGISTRATE JUDGE

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