izmo CRM, Inc v. Prize Corporation

Filing 73

Order by Hon. Lucy H. Koh granting 64 Motion for Extension of Time to Complete Discovery. (lhklc2, COURT STAFF) (Filed on 6/1/2011)

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fg.hl oiNapoli (State Bar No. 84365)
[e-mail]
Steven J. Sibley (State Bar No. 152365)
[e-mail]
DINAPOLI & SIBLEY
Ten Almaden Boulevard, Suite 1250
San Jose, CA 95ll3-2271
Telephone: [phone]
Facsimile: [phone]
ed Pro Hac Vice)

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FARRIS BOBANGO BRANAN PLC
One Comemrce Square, Suite 2000
40 South Main Street
Memphis, TN 38103
Telephone: [phone]
Facsimile: (901) 259 -7 | 50

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Attorneys for defendant and Counterclaimant
PRIZE CORPORATION

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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CASENO.

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Plaintifl

LHK

STIPULATED REQUEST F'OR ORDER
AND [PROPOSED] ORDER EXTENDING
DISCOVERY DEADLINE

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C1O-00518

PRIZE CORPORATION, and DOES
through 20, inclusive,

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Defendants.

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AN D RELATE D

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Pursuant

to Civil Local Rules 6-2 and 7-I2, this Stipulation and Order to Extend

the

Discovery Cut-Off (the "Stipulation and Order") is made by and between Plaintiff and Counterdefendant izmo CRM, Inc. and Defendant and Counterclaimant Prize Corporation in the above-

captioned matter for the limited pu(pose of allowing additional time for Prize Corporation to

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OPKINS

& CARLEY

ATToSNEYS AT LAw

S^N rosE

FOR ORDER AND [PROPOSED] ORDER
STIPULATED
EXTENDING DISCOVERY DEADLINE

CASENO, C-IO-OO5I8 LHK

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depose Tej Soni, the president of izmo CRM, Inc. and to take the deposition of izmo CRM, Inc.'s

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designated representative per FRCP 30(bX6).

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By order of this court dated April 14, 20II, all discovery in this matter shall be completed

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by May 13,2011. Mr. Soni was noticed on

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the representative(s) of izmo CRM, Inc, were noticed on

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on May

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States

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Counsel

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representative for the 30(b)(6) deposition, The parties hereby agree and stipulate to extend the

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discovery cut-off date for the limited pu{pose of deposing Mr. Soni and izmo CRM per the

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deposition notices. Mr, Soni has agreed to present himself for deposition between June

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June 3.

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April 15,2011 for a deposition on April 28,2011 and
April 19,2011 for a 30(b)(6) deposition

2,2011. Per counsel for izmo CRM, Inc., Tej Soni,

a citizen of India, is out of the United

until the end of May and carurot present himself for deposition at the noticed times.

for izmo CRM; Inc,

has represented that

Mr. Soni will also be a

designated

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Provided that Mr. Soni is available for each deposition on two of the three days June 1 -

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3, counsel do not anticipate that the requested time modification

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will have any other effect on the

schedule for the case.

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In the event lhat izmo CRM determines that Mr. Soni will not be its

designated

wiil apply to the deposition

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representative for the 30(b)(6) deposition, the same extension of time

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of whomever it designates in his place and izmo CRM will provide that witness for deposition

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before the expiration of the extended deadline.

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':::Ilf :it;"

STIPULATED REQUEST FOR ORDER AND IPROPOSED] ORDER
EXTENDING DISCOVERY DEADLINE

CASENO, C-r0-00sr8 LHK

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AprillL ,2011

Dated:
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HOPKINS & CARLEY
A Law Corporation

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Bv: SJ"iA E. /

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Daniel F. Pyne
Shirley E. Jackson
Attomeys for Plaintiff and Counterdefendant
izmo CRM, INC.
Dated:

April

,2011

FARRIS BOBANGO BRANAN PLC

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Attorneys for Defendant and Counterclaimant
PRIZE CORPORATION

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ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated: June 1, 2011
April _, 2011

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HON. LUCY H. KOH

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?i:ill,t:it'"
SAN JosE

000\84 1214.

IPULATED REQUEST FOR ORDER AND IPROPOSE
EXTENDING DISCOVERY DEADLINE

cAsE NO. C-l0-00518 LHK