Interserve, Inc. et al v. Fusion Garage PTE. LTD
Filing
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STIPULATION Continuing Date Written Discovery Responses Are Due by CrunchPad, Inc., Fusion Garage PTE. LTD, Interserve, Inc.. (Pennypacker, Evette) (Filed on 12/15/2011)
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David S. Bloch (SBN: 184530)
dbloch@winston.com
J. Caleb Donaldson (SBN: 257271)
jcdonaldson@winston.com
WINSTON & STRAWN LLP
101 California Street
San Francisco, CA 94111-5802
Telephone:
(415) 591-1000
Facsimile:
(415) 591-1400
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Attorneys for Plaintiffs
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101 California Street
San Francisco, CA 94111-5802
Winston & Strawn LLP
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QUINN EMANUEL URQUHART & SULLIVAN, LLP
Claude M. Stern (Bar No. 96737)
claudestern@quinnemanuel.com
Evette Pennypacker (Bar No. 203515)
evettepennypacker@quinnemanuel.com
Thomas R. Watson (Bar No. 227264)
555 Twin Dolphin Dr., 5th Floor
Redwood Shores, Ca 94065
Telephone: (650) 801-5000
Facsimile: (650) 801-5100
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Attorneys for Defendant
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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TECHCRUNCH, INC., et al.
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Plaintiffs,
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vs.
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FUSION GARAGE PTE. LTD.,
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Defendant.
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Case No. 3:09-cv-05812 RS (PSG)
JOINT STIPULATION AND [PROPOSED]
ORDER CONTINUING DATE WRITTEN
DISCOVERY RESPONSES ARE DUE
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04049.51632/4510912.1
Case No. 3:09-cv-05812 RS (PSG)
JOINT STIPULATION AND [PROPOSED] ORDER
CONTINUING DATE WRITTEN DISCOVERY RESPONSES ARE DUE
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WHEREAS, the parties engaged in private mediation on September 21, 2011, and executed a
Memorandum of Understanding regarding final settlement of this case at the mediation;
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WHEREAS, the parties sought a stay pending the execution of a definitive agreement, which
was granted by Judge Richard Seeborg on September 23, 2011 (Dkt. 216);
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WHEREAS, the parties were unable to reach a final agreement regarding settlement despite
lengthy and good faith settlement negotiations (Dkt. 217, 219, 220);
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WHEREAS, prior to the Court ordered stay, the parties propounded the following sets of
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written discovery: Defendant’s Requests for Production (Set 4), Interrogatories (Set 3), and
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Requests for Admission (Set 1); and Plaintiffs’ Requests For Production (Set 8) and Interrogatories
101 California Street
San Francisco, CA 94111-5802
Winston & Strawn LLP
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(Set 4) (collectively, “Written Discovery”);
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WHEREAS, the parties had previously stipulated to serve responses to the Written Discovery
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on December 16, 2011, which was approved by the Court in an order dated November 11, 2011
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(Dkt. 221, Dkt. 222);
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WHEREAS, Defendant filed a Motion to Compel Production of Documents on September 9,
2011 (Dkt. 212);
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WHEREAS, in accordance with the parties’ stipulated schedule, approved by the Court in an
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order dated November 11, 2011 (Dkt. 221, Dkt. 222), Plaintiffs filed an Opposition to the Motion to
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Compel on December 2, 2011 (Dkt. 226);
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WHEREAS, the Court entered an order scheduling the hearing on the Motion to Compel on
January 3, 2012 (Dkt. 224);
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WHEREAS, Quinn Emanuel Urquhart & Sullivan, LLP filed a motion to withdraw as
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counsel of record for Fusion Garage on December 13, 2011 (“Quinn Emanuel’s Motion”) (Dkt.
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230);
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NOW THEREFORE, it is hereby stipulated by the undersigned counsel on behalf of the
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parties identified below that, subject to Court approval, the December 16, 2011 date to provide
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responses to the parties’ Written Discovery, shall be continued to a date mutually agreeable between
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the parties in light of Quinn Emanuel’s Motion.
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04049.51632/4510912.1
-1-
Case No. 3:09-cv-05812 RS (PSG)
JOINT STIPULATION AND [PROPOSED] ORDER
CONTINUING DATE WRITTEN DISCOVERY RESPONSES ARE DUE
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NOW THEREFORE, it is hereby further stipulated by the undersigned counsel on behalf of
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the parties identified below that, subject to Court approval, the Motion to Compel shall be
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withdrawn, without prejudice to its reintroduction after the resolution of Quinn Emanuel’s Motion.
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Dated: December 15, 2011
WINSTON & STRAWN LLP
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By:
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/s/
David S. Bloch
Attorneys for Plaintiffs
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101 California Street
San Francisco, CA 94111-5802
Winston & Strawn LLP
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Dated: December 15, 2011
QUINN EMANUEL URQUHART & SULLIVAN, LLP
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By:
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/s/
Evette D. Pennypacker
Attorneys for Defendant
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PURSUANT TO STIPULATION, IT IS SO ORDERED:
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DATED: December ___, 2011
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The Honorable Richard Seeborg
United States District Court Judge
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04049.51632/4510912.1
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Case No. 3:09-cv-05812 RS (PSG)
JOINT STIPULATION AND [PROPOSED] ORDER
CONTINUING DATE WRITTEN DISCOVERY RESPONSES ARE DUE
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ATTESTATION
I, Evette D. Pennypacker, hereby attest, pursuant to N.D. Cal. General Order No. 45, that I
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have obtained the concurrence to the filing of this document of each signatory hereto.
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By:
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/s/
Evette D. Pennypacker
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101 California Street
San Francisco, CA 94111-5802
Winston & Strawn LLP
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04049.51632/4510912.1
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Case No. 3:09-cv-05812 RS (PSG)
JOINT STIPULATION AND [PROPOSED] ORDER
CONTINUING DATE WRITTEN DISCOVERY RESPONSES ARE DUE
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