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

Filing 71

STIPULATION AND [PROPOSED] ORDER TO EXTEND CERTAIN DISCOVERY CUT-OFF DATES by IO Group, Inc.. (Sperlein, D.) (Filed on 5/29/2007)

Download PDF
IO Group, Inc. v. Veoh Networks, Inc. Doc. 71 Case 5:06-cv-03926-HRL Document 71 Filed 05/29/2007 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 GILL SPERLEIN (172887) THE LAW FIRM OF GILL SPERLEIN 584 Castro Street, Suite 849 San Francisco, California 94114 Telephone: (415) 487-1211 X32 Facsimile: (415) 252-7747 legal@titanmedia.com 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 CERTAIN 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 Network, Inc., hereby stipulate to extend certain discovery cutoff dates. The extension of time is necessary in order to schedule three depositions that the parties were unable to schedule prior to the May 30, 2007 cut-off date in spite of their best efforts to do so. Parties merely seek to extend discovery for the limited purpose of plaintiff's third party depositions of John "Halcyon" Styn, Shelter Capital, LLC and Tornante, LCC. All depositions will be complete by June 7, 2007. Previously, stipulations and orders resulted in the following time modifications. -1STIPULATION AND [PROPOSED] ORDER C-06-3926 (HRL) Dockets.Justia.com Case 5:06-cv-03926-HRL Document 71 Filed 05/29/2007 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 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, Parties 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. On April 18, 2007 parties stipulated to extend discovery until May 30, 2007 and on April 23, 2007, the Court so ordered. This stipulation and proposed order, if issued, would extend discovery for the limited purpose of plaintiff's third party depositions of John "Halcyon" Styn, Shelter Capital, LLC, and Tornante, LCC. Also the date to file any motion to compel relating to these three depositions would be extended until ten days after the scheduled deposition dates. No other dates would be effected. WHEREAS the Court previously set May 30, 2007 as the deadline for fact discovery; WHEREAS parties have attempted to meet and confer with regard to scheduling Plaintiff's deposition of John "Halycon" Styn, Shelter Capital, LLC and Tornante, LLC but have been unable to secure a date prior to May 30, 2007 in spite of their best efforts; The parties do therefore stipulate and agree as follows: -2STIPULATION AND [PROPOSED] ORDER C-06-3926 (HRL) Case 5:06-cv-03926-HRL Document 71 Filed 05/29/2007 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 1. To extend fact discovery cutoff for the limited purpose of plaintiff's deposition of John "Halcyon" Styn which is to take place on Thursday May 31, 2007 at 10:00 a.m. in San Diego, California. 2. To extend fact discovery cutoff for the limited purpose of plaintiff's depositions of Shelter Capital, LLC on June 5, 2007 at 1pm, and Tornante, LLC on June 7, 2007 at 2pm, both in Los Angeles, California. 3. 4. 5. To extend the deadline for filing any motion to compel relating to the taking of the Counsel for Defendant Veoh Networks is working to coordinate the depositions of This stipulation does not effect due dates of any outstanding discovery requests. above referenced depositions until June 22, 2007. the third parties referenced above at the times referenced above. SO STIPULATED. Dated: 5/29/2007 /s/ Gill Sperlein Gill Sperlein THE LAW FIRM OF GILL SPERLEIN Attorney's for Plaintiff Dated: 5/29/2007 /s/ Jennifer A. Golinveaux Jennifer A. Golinveaux WINSTON & STRAWN, LLP Attorney's for Defendant [PROPOSED] ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED. Dated: HONORABLE HOWARD R. LLOYD UNITED STATES MAGISTRATE JUDGE SF:173395.1 -3STIPULATION AND [PROPOSED] ORDER C-06-3926 (HRL)

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?