Leader Technologies, Inc., v. Facebook, Inc.

Filing 44

Declaration of Sean M. Boyle in Support of 43 MOTION to Shorten Time for Hearing of Motion for De Novo Review and to Expand the Record filed byLeader Technologies, Inc.,. (Related document(s) 43 ) (Boyle, Sean) (Filed on 3/26/2010)

Leader Technologies, Inc., v. Facebook, Inc.

Doc. 44

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J. Andrew Coombs (SBN 123881) [e-mail] Annie S. Wang (SBN 243027) [e-mail] J. Andrew Coombs, A Prof. Corp. 517 East Wilson Avenue, Suite 202 Glendale, California 91206 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff Louis Vuitton Malletier, S.A. GAUNTLETT & ASSOCIATES James A. Lowe (SBN 214383) [e-mail] Brian S. Edwards (SBN 166258) [e-mail] 18400 Von Karman, Suite 300 Irvine, California 92612 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants Akanoc Solutions, Inc., Managed Solutions Group, Inc., Steven Chen UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA Louis Vuitton Malletier, S.A., Plaintiff, v. Akanoc Solutions, Inc., et al., Defendants. ) ) ) ) ) ) ) ) ) ) Case No.: C 07 3952 JW JOINT STIPULATION AND [PROPOSED] ORDER GRANTING LIMITED ENLARGEMENT OF THE DISCOVERY CUT-OFF DATE

Plaintiff Louis Vuitton Malletier, S.A. ("Plaintiff") and Defendants Akanoc Solutions, Inc., Managed Solutions Group, Inc. and Steven Chen (collectively "Defendants') by and through their respective counsel of record agree and stipulate as follow:

Louis Vuitton v. Akanoc, et al.: Stipulation re Discovery Cut-off

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Dockets.Justia.com

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WHEREAS the Court has entered a Scheduling Order in the above-captioned matter setting, among other things, a discovery cut-off date of April 28, 2008; and WHEREAS the Plaintiff served notices of depositions setting the depositions of two employees of Defendant Akanoc Solutions, Inc., on April 23, 2008, in Pleasanton within the Northern District of California within the discovery cut-off; and WHEREAS Magistrate Judge Lloyd entered an order compelling the appearance of Plaintiff's designee to testify on issues as provided by Fed.R.Civ.P. 30(b)(6) and the best mutually acceptable date on which to conduct that deposition is April 23, 2008; and WHEREAS a motion to compel production is on calendar before Magistrate Judge Lloyd for April 29, 2008; NOW, THEREFORE, Plaintiff and Defendants stipulate and agree that the Discovery Cutoff may, subject to order of this Court, be enlarged to April 29, 2008 for the limited purpose of taking the depositions of the two employees of defendant Akanoc Solutions, Inc. previously noticed by Plaintiff. Dated: April 22, 2008 J. Andrew Coombs, A Professional Corp. By: __/s/ J. Andrew Coombs__________________ J. Andrew Coombs Annie S. Wang Attorneys for Plaintiff Louis Vuitton Malletier, S.A. Dated: April 23, 2008 GAUNTLETT & ASSOCIATES By: ____/s/ James A. Lowe____________________ James A. Lowe Brian S. Edwards Attorneys for Defendants Akanoc Solutions, Inc., Managed Solutions Group, Inc., Steven Chen IT IS SO ORDERED . All other dates set in the November 13, 2007 scheduling order remain unchanged. Last date to hear date dispositive motions set for June 30, 2008. Preliminary Pretrial and Trial Setting Conference set for September 8, 2008 at__, 2008 11:00 AM. April _________________________________________
Dated: April 24, 2008

Hon. James Ware District Judge, Northern District of California
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Louis Vuitton v. Akanoc, et al.: Stipulation re Discovery Cut-off

PROOF OF SERVICE I, the undersigned, certify and declare that I am over the age of 18 years, employed in the County of Los Angeles, and not a party to the above-entitled cause. I am employed by a member of the Bar of the United States District Court of California. My business address is 517 E. Wilson Ave., Suite 202, Glendale, California 91206. On April 23, 2008, I served on the interested parties in this action with the: JOINT STIPULATION AND [PROPOSED] ORDER GRANTING LIMITED ENLARGEMENT OF THE DISCOVERY CUT-OFF DATE for the following civil action: Louis Vuitton Malletier S.A. v. Akanoc Solutions, Inc., et al. by placing a true copy thereof in an envelope to be immediately sealed thereafter. I am readily familiar with the office's practice of collecting and processing correspondence for mailing. Under that practice it would be deposited with the United States Postal Service on the same day with postage thereon fully prepaid at Glendale, California in the ordinary course of business. I am aware that on motion of the party served, service presumed invalid if postal cancellation date or postage meter is more than one day after date of deposit for mailing in affidavit. James A. Lowe Brian S. Edwards Gauntlett & Associates 18400 Von Karman Ave., Suite 300 Irvine, California 92612 Place of Mailing: Glendale, California Executed on April 23, 2008, at Glendale, California.