Shepherd et al v. S3 Partners, LLC et al

Filing 64

AMENDED STIPULATION AND ORDER 62 to Extend Deadline to Complete Discovery and Alternative Dispute Resolution. Jury Selection set for 8/29/2011 01:30 PM in Courtroom 6, 4th Floor, San Jose before Hon. Ronald M. Whyte. Motion Hearing set for 7/8/201 1 09:00 AM in Courtroom 6, 4th Floor, San Jose before Hon. Ronald M. Whyte. Pretrial Conference set for 8/11/2011 02:00 PM in Courtroom 6, 4th Floor, San Jose before Hon. Ronald M. Whyte. Signed by Judge Ronald M. Whyte on 4/15/11. (jg, COURT STAFF) (Filed on 4/15/2011)

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1 2 3 4 5 6 7 GREGORY CHARLES, ESQ., BAR NO. 208583 CAMPEAU GOODSELL SMITH 440 North First Street, Ste. 100 San Jose, California 95112 Telephone: 408.295.9555 Facsimile: 408.852.0233 gcharles@campeaulaw.com *E-FILED - 4/15/11* Counsel for S3 Partners, LLC; The Shields Foundation; Northwest Consulting Group, LLC; Livingstone Capital; Stagecoach Retail, LLC; Sonterra Retail Center, LLC; and Melvin Russell Shields 8 9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 SAN JOSE DIVISION 13 A Law Corporation San Jose, California CAMPEAU GOODSELL SMITH 12 MARK SHEPHERD AND DELIA SHEPHERD 14 PLAINTIFFS, 15 16 17 18 19 20 21 V. Case No. 09-CV-01405 RMW *AMENDED* STIPULATION TO EXTEND DEADLINETO COMPLETE DISCOVERY AND ALTERNATIVE DISPUTE RESOLUTION AND ORDER. S3 PARTNERS, LLC, ALARIS DEVELOPMENT; THE SHIELDS FOUNDATION; NORTHWEST CONSULTING GROUP, LLC; CORINTHIAN WEALTH MANAGEMENT; GOLDEN CREST WEALTH MANAGEMENT; PIERCE ARROW INVESTORS, LLC; LIVINGSTONE CAPITAL; STAGECOACH RETAIL, LLC; SONTERRA RETAIL CENTER, LLC; MICHAEL SIMS; SAM STAFFORD; MELVIN RUSSELL SHIELDS; DAVID VAUGHN; DAVID SAMUELS; CHASTAN SHIELDS; AND DOUG BURKE, 22 No Hearing Defendants. 23 STIPULATION 24 25 26 1. On October 26, 2010, an order issued appointing Paul A. Renne, Esq. as mediator in this. 27 2. The parties have not conducted depositions in this matter. 28 3. S3 Partners, LLC; The Shields; Foundation; Northwest Consulting Stipulation and Order 1 1 Group, LLC; Livingstone Capital; Stagecoach Retail, LLC; Sonterra Retail Center, 2 LLC; Melvin Russell Shields; and Chastan Shields (the “Shields Defendants”) desire to 3 take the deposition of the plaintiffs before a mediation of the dispute. 4. 4 Mark and Delia Sheppard previously noticed for March 22, 2011 and 5 desire to take the deposition of Melvin Russell Shields before a mediation of the 6 dispute. Mr. Shields lives in North Carolina and was not available to travel to 7 California for the date that his deposition was noticed. His deposition was 8 rescheduled by consent of counsel for April 13, 2011. 5. 9 10 The current discovery cutoff for percipient witnesses on April 29, 2011 and the Trial Date is August 29, 2011; Pretrial Conference is August 11, 2011. June 1, 2011. 13 A Law Corporation San Jose, California 6. 12 CAMPEAU GOODSELL SMITH 11 7. The Parties desire to extend the completion of discovery until May 28, 8. The Parties desire to extend the deadline to file dispositive motions to 14 15 16 The parties desire to extend the time to complete the mediation until 2011. June 1, 2011 and last date to hear dispositive motions is July 8, 2011. 17 So Stipulated. 18 Dated: April 7, 2011 19 CAMPEAU GOODSELL SMITH A Law Corporation By: 20 21 22 23 24 25 Dated: April 7, 2011 /s/ Gregory J. Charles Gregory J. Charles Attorneys for S3 Partners, LLC; The Shields Foundation; Northwest Consulting Group, LLC; Livingstone Capital; Stagecoach Retail, LLC; Sonterra Retail Center, LLC; Melvin Russell Shields; and Chastan Shields RICE & BRONITSKY 26 27 28 By: s/ Paul E. Rice Paul E. Rice Stipulation and Order 2 _________ Attorneys for Plaintiffs Mark Shepherd and Delia Shepherd 1 2 3 4 5 6 So Ordered. 15 Dated: April ___, 2011 ______________________________________ Ronald M. Whyte United States District Court Judge 7 8 9 10 11 13 A Law Corporation San Jose, California CAMPEAU GOODSELL SMITH 12 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Stipulation and Order 3

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