MSGI Security Solutions, Inc. v. Hyundai Syscomm Corporation et al

Filing 127

STIPULATION AND ORDER RE 126 TO EXTEND DISCOVERY CUT-OFF DATES. Stipulation filed by MSGI Security Solutions, Inc. Signed by Judge Richard Seeborg on 10/18/11. (cl, COURT STAFF) (Filed on 10/18/2011)

Download PDF
E-Filed 10/18/11* 1 2 3 4 WILLIAM J. GOINES (SBN: 61290) ALICE Y. CHU (SBN: 264990) GREENBERG TRAURIG, LLP 1900 University Avenue, Fifth Floor East Palo Alto, California 94303 Telephone: (650) 328-8500 Facsimile: (650) 328-8508 Email: goinesw@gtlaw.; chua@gtlaw.com 5 6 7 8 9 Attorneys for Plaintiff MSGI Security Solutions, Inc. DENNIS DEAN BROWN LAW OFFICES OF DENNIS D. BROWN 111 N. Market Street, Ste. 1010 San Jose, Ca 95113-1112 Telephone: (408) 277-0727 Email: Ddb-law@pacbell.net 10 11 12 Attorney for Defendants Hyundai Syscomm Corporation, Hyundai Syscomm Inc., Apro Media Corporation, Hirsch Group LLLP, Hirsch Capital Corporation, Hyundai RFMON Corporation, Samuel Lee, Jack Choe, Benjamin Byun, Wallace Benjamin Garst, Jr., and David Choe 13 14 UNITED STATES DISTRICT COURT 15 NORTHERN DISTRICT OF CALIFORNIA 16 17 MSGI SECURITY SOLUTIONS, INC., a New York Corporation, 18 Case No. C09-03330-RS STIPULATION TO EXTEND DISCOVERY CUT-OFF DATES AND [PROPOSED] ORDER Plaintiff; 19 v. 20 HYUNDAI SYSCOMM CORPORATION, et al., 21 Defendants. 22 23 AND RELATED COUNTERCLAIM 24 25 TO ALL PARTIES AND TO THEIR RESPECTIVE ATTORNEYS OF RECORD: 26 This Stipulation is pursuant to Civil L.R. 6-2 and is made between Plaintiff MSGI Security 27 Solutions, Inc. (hereinafter “Plaintiff” or “MSGI”) and Defendants Hyundai Syscomm Corporation, 28 Hyundai Syscomm Inc., Apro Media Corporation, Hirsch Group LLLP, Hirsch Capital Corporation, STIPULATION TO EXTEND DISCOVERY CUT-OFF AND [PROPOSED] ORDER C09-03330-RS SV 346,776,955v1 1 Hyundai RFMON Corporation, Samuel Lee, Jack Choe, Benjamin Byun, Wallace Benjamin Garst, 2 Jr., and David Choe (collectively known as “Defendants”), by and through their respective counsel. 3 The parties herein agree and stipulate as follows: 4 5 1. California, San Jose Division; 6 7 2. 10 On February 15, 2011, William J. Goines of Greenberg Traurig, LLP entered an appearance as counsel for Plaintiff; 8 9 On or about July 21, 2009, this action was filed with the Northern District of 3. Pursuant to the Case Management Scheduling Order filed March 17, 2011 [ECF Doc. #123](“March 17, 2011 Order”), the Court established the following discovery deadlines, with a trial date set for July 23, 2012: 11 (a) Completion of non-expert discovery: October 30, 2011; 12 (b) Plaintiff’s disclosure of expert testimony and reports: November 30, 2011; 13 (c) Defendants’ disclosure of expert testimony and reports: December 30, 2011; 14 (d) Parties’ disclosure of rebuttal expert disclosures and exchange of reports: January 30, 15 2012; 16 (e) Completion of expert witness discovery: March 15, 2012. 17 4. The parties participated in a mediation with Walter J. Robinson on June 30, 2011 and 18 have maintained a continuous dialogue since that time to see if a mutually acceptable settlement of 19 Plaintiff’s claims may be achieved; 20 5. In light of their ongoing settlement discussions, the Parties believe that a 45-day 21 extension of the discovery deadlines in the March 17, 2011 Order will significantly aid their 22 settlement efforts such that the Parties may engage in additional settlement discussions and allocate 23 their time and resources to such discussions; 24 25 6. 7. The requested extensions will not affect other dates set forth in the March 17, 2011 Order; 26 27 This is the first request for extension of the dates set forth in the March 17, 2011 Order; 28 -2 - STIPULATION TO EXTEND DISCOVERY CUT-OFF AND [PROPOSED] ORDER CASE NO.C09-03330-RS SV 346,776,955v1 1 2 8. Mediator Walter J. Robinson is continuing to work with the Parties and recommends extending the discovery deadlines to aid settlement efforts. 3 IT IS HEREBY STIPULATED by and between the parties to the above-entitled action, 4 through their respective counsel, that the Court may enter an order extending by forty-five (45) days 5 the current discovery deadlines as follows: 6 (a) Completion of non-expert discovery: 7 Old Date: October 30, 2011 8 New Date: December 14, 2011 9 (b) Plaintiff’s disclosure of expert testimony and reports: 10 Old Date: November 30, 2011 11 New Date: January 13, 2012 12 (c) Defendants’ disclosure of expert testimony and reports: 13 Old Date: December 30, 2011 14 New Date: February 13, 2012 15 (d) Parties’ disclosure of rebuttal expert disclosures and exchange of reports: 16 Old Date: January 30, 2012 17 New Date: March 15, 2012 18 (e) Completion of expert witness discovery: 19 Old Date: March 15, 2012 20 New Date: April 30, 2012 21 22 Dated: October 18, 2011. Respectfully submitted, 23 GREENBERG TRAURIG, LLP 24 By: /s/ William J. Goines William J. Goines Attorney for Plaintiff and Counter Defendant MSGI Security Solutions, Inc. 25 26 27 28 -3 - STIPULATION TO EXTEND DISCOVERY CUT-OFF AND [PROPOSED] ORDER CASE NO.C09-03330-RS SV 346,776,955v1 1 Dated: October 18, 2011. LAW OFFICES OF DENNIS D. BROWN 2 By: /s/ Dennis D. Brown Dennis D. Brown Attorney for Defendants 3 4 ATTESTATION CLAUSE 5 I, William J. Goines, am the ECF User whose ID and password are being used to file this 6 7 8 9 STIPULATION TO EXTEND DISCOVERY CUT-OFF DATES AND [PROPOSED] ORDER. In compliance with General Order 45, X.B., I hereby attest that Dennis D. Brown has concurred in this filing. 10 11 Date: October 18, 2011. GREENBERG TRAURIG LLP 12 By: /s/ William J. Goines 13 14 15 16 17 [PROPOSED] ORDER 18 19 GOOD CAUSE APPEARING, IT IS SO ORDERED. 20 Dated: 10/18/11 . 21 22 23 Hon. Richard Seeborg Judge, United States District Court 24 25 26 27 28 -4 - STIPULATION TO EXTEND DISCOVERY CUT-OFF AND [PROPOSED] ORDER CASE NO.C09-03330-RS SV 346,776,955v1

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?