Interserve, Inc. et al v. Fusion Garage PTE. LTD

Filing 232

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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1 5 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 6 Attorneys for Plaintiffs 2 3 4 7 8 9 101 California Street San Francisco, CA 94111-5802 Winston & Strawn LLP 10 11 12 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 13 Attorneys for Defendant 14 15 UNITED STATES DISTRICT COURT 16 NORTHERN DISTRICT OF CALIFORNIA 17 SAN FRANCISCO DIVISION 18 TECHCRUNCH, INC., et al. 19 Plaintiffs, 20 vs. 21 FUSION GARAGE PTE. LTD., 22 Defendant. 23 ) ) ) ) ) ) ) ) ) ) Case No. 3:09-cv-05812 RS (PSG) JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING DATE WRITTEN DISCOVERY RESPONSES ARE DUE 24 25 26 27 28 04049.51632/4510912.1 Case No. 3:09-cv-05812 RS (PSG) JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING DATE WRITTEN DISCOVERY RESPONSES ARE DUE 1 2 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; 3 4 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); 5 6 WHEREAS, the parties were unable to reach a final agreement regarding settlement despite lengthy and good faith settlement negotiations (Dkt. 217, 219, 220); 7 WHEREAS, prior to the Court ordered stay, the parties propounded the following sets of 8 written discovery: Defendant’s Requests for Production (Set 4), Interrogatories (Set 3), and 9 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 10 (Set 4) (collectively, “Written Discovery”); 11 WHEREAS, the parties had previously stipulated to serve responses to the Written Discovery 12 on December 16, 2011, which was approved by the Court in an order dated November 11, 2011 13 (Dkt. 221, Dkt. 222); 14 15 WHEREAS, Defendant filed a Motion to Compel Production of Documents on September 9, 2011 (Dkt. 212); 16 WHEREAS, in accordance with the parties’ stipulated schedule, approved by the Court in an 17 order dated November 11, 2011 (Dkt. 221, Dkt. 222), Plaintiffs filed an Opposition to the Motion to 18 Compel on December 2, 2011 (Dkt. 226); 19 20 WHEREAS, the Court entered an order scheduling the hearing on the Motion to Compel on January 3, 2012 (Dkt. 224); 21 WHEREAS, Quinn Emanuel Urquhart & Sullivan, LLP filed a motion to withdraw as 22 counsel of record for Fusion Garage on December 13, 2011 (“Quinn Emanuel’s Motion”) (Dkt. 23 230); 24 NOW THEREFORE, it is hereby stipulated by the undersigned counsel on behalf of the 25 parties identified below that, subject to Court approval, the December 16, 2011 date to provide 26 responses to the parties’ Written Discovery, shall be continued to a date mutually agreeable between 27 the parties in light of Quinn Emanuel’s Motion. 28 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 1 NOW THEREFORE, it is hereby further stipulated by the undersigned counsel on behalf of 2 the parties identified below that, subject to Court approval, the Motion to Compel shall be 3 withdrawn, without prejudice to its reintroduction after the resolution of Quinn Emanuel’s Motion. 4 Dated: December 15, 2011 WINSTON & STRAWN LLP 5 6 By: 7 8 /s/ David S. Bloch Attorneys for Plaintiffs 9 101 California Street San Francisco, CA 94111-5802 Winston & Strawn LLP 10 Dated: December 15, 2011 QUINN EMANUEL URQUHART & SULLIVAN, LLP 11 By: 12 13 /s/ Evette D. Pennypacker Attorneys for Defendant 14 15 16 PURSUANT TO STIPULATION, IT IS SO ORDERED: 17 18 DATED: December ___, 2011 19 20 21 The Honorable Richard Seeborg United States District Court Judge 22 23 24 25 26 27 28 04049.51632/4510912.1 -2- Case No. 3:09-cv-05812 RS (PSG) JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING DATE WRITTEN DISCOVERY RESPONSES ARE DUE 1 2 ATTESTATION I, Evette D. Pennypacker, hereby attest, pursuant to N.D. Cal. General Order No. 45, that I 3 have obtained the concurrence to the filing of this document of each signatory hereto. 4 By: 5 /s/ Evette D. Pennypacker 6 7 8 9 101 California Street San Francisco, CA 94111-5802 Winston & Strawn LLP 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 04049.51632/4510912.1 -3- Case No. 3:09-cv-05812 RS (PSG) JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING DATE WRITTEN DISCOVERY RESPONSES ARE DUE

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