C&C Jewelry Mfg Inc v. Trent West

Filing 135

STIPULATION AND ORDER FOR ENTRY OF SUBSEQUENT CASE MANAGEMENT SCHEDULE SETTING CASE SCHEDULE THROUGH TRIAL re 122 . Signed by Judge Jeremy Fogel on 11/23/10. (dlm, COURT STAFF) (Filed on 12/2/2010)

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Edward Vincent King, Jr. (SBN 085726) KING & KELLEHER, LLP Four Embarcadero Center, 17th Floor San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] [e-mail] Attorneys for Defendant TRENT WEST DURIE TANGRI LLP DARALYN J. DURIE (Bar No. 169825) RYAN M. KENT (Bar No. 220441) 217 Leidesdorff Street San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] STORM LLP John G. Fischer (pro hac vice) Paul V. Storm (pro hac vice) 901 Main Street, Suite 7100 Dallas, Texas 75202 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] Attorneys for Plaintiff C&C JEWELRY MANUFACTURING, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ­ SAN JOSE DIVISION C&C JEWELRY MFG., INC., Plaintiff, v. TRENT WEST, Defendant. ___________________________________ And Related Counterclaims Case No. 5:09-cv-01303-JF JOINT STIPULATION FOR ENTRY OF SUBSEQUENT CASE MANAGEMENT SCHEDULE SETTING CASE SCHEDULE THROUGH TRIAL

JOINT STIPULATION FOR ENTRY OF SUBSEQUENT CASE MANAGEMENT SCHEDULE

Case No. 5:09-CV-01303-JF

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At the parties' subsequent case management conference under Civil L.R. 16-10(c), conducted before the Court on July 30, 2010 (see the Court's Minute Order at Docket Entry No. 96), the Court set the date for the pre-trial conference in this matter for April 1, 2011 and scheduled trial to begin on April 8, 2011. The Court left it to the parties to agree to and propose, for the Court's approval, dates for the other case milestones leading up to trial. Accordingly, Defendant Trent West ("West") and Plaintiff C&C Jewelry Mfg., Inc. ("C&C"), by and through their undersigned counsel of record, have agreed and hereby submit this joint stipulated request, pursuant to Civil L.R. 16-10(d), Civil L.R. 6 and the Court's Minute Order of July 30, 2010, for entry of the following case management schedule for conducting the litigation of this matter through trial: Event Advice of Counsel - Willfulness Opinion Disclosure under Patent L.R. 3-7 (50 days after service by the Court of its Claim Construction Ruling ­ but extended per C&C's request) Expert disclosure and serve reports by party with the burden of proof on an issue Fact discovery cut off (serve discovery requests and notice fact witness depositions to be completed by this date) Expert disclosure and serve rebuttal reports by party without the burden of proof on an issue Last day to file dispositive motions Expert discovery cut off ­ complete expert witness depositions by this date Last day to file Daubert motions objecting to experts Last day to hear dispositive motions Meeting of Counsel for Pre-trial Conference Statement preparation File Joint Pre-trial Conference Statement Pre-trial Conference Trial Proposed Dates September 24, 2010

December 17, 2010 December 17, 2010 January 17, 2011 February 7, 2011 February 9, 2011 February 18, 2011 March 14, 2011 March 15, 2011 March 23, 2011 April 1, 2011 April 8, 2011

JOINT STIPULATION FOR ENTRY OF SUBSEQUENT CASE MANAGEMENT SCHEDULE

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Case No. 5:09-CV-01303-JF

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The parties completed Court-sponsored mediation in July. Pursuant to stipulation and the Court's instructions, West and C&C respectfully request the Court to enter the above stipulated case management schedule dates for conducting this matter through trial.

Respectfully stipulated to by: KING & KELLEHER, LLP By: /s/ Edward Vincent King, Jr. Edward Vincent King, Jr. Attorneys for Defendant Trent West Date: October 13, 2010 STORM LLP By: /s/ Paul V. Storm_ Paul V. Storm Attorneys for Plaintiff C&C Jewelry Mfg., Inc. Date: October 13, 2010

PURSUANT TO STIPULATION, it is hereby ordered that the above stipulated case management schedule shall be entered in this matter. 23 DATED: November ___, 2010

/s/ Hon. Jeremy Fogel United States District Judge

JOINT STIPULATION FOR ENTRY OF SUBSEQUENT CASE MANAGEMENT SCHEDULE

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Case No. 5:09-CV-01303-JF