Joe Hand Promotions Inc v. Nguyen

Filing 37

ORDER Modifying Case Schedule. Signed by Judge Lucy H. Koh on 11/17/2011. (lhklc1, COURT STAFF) (Filed on 11/17/2011)

1 Sayuri K. Sharper (Bar No. 232331)
[e-mail]
2 PRO BONO PROJECT SILICON VALLEY
480 N. First Street
3 San Jose, CA 95112
Telephone: [phone]
4 Facsimile: [phone]
5 Attorney for Defendant Ngoc Ha T. Nguyen
6 Thomas P. Riley (Bar No. 194706)
[e-mail]
7 LAW OFFICES OF THOMAS P. RILEY, P.C.
First Library Square
8 1114 Fremont Avenue
South Pasadena, CA 91030
9 Telephone: [phone]
Facsimile: [phone]
10
Attorneys for Plaintiff Joe Hand Promotions, Inc.
11
12

UNITED STATES DISTRICT COURT

13

NORTHERN DISTRICT OF CALIFORNIA

14

San Jose Division

15
16 JOE HAND PROMOTIONS, INC.,
17

Plaintiff,

18 v.
19 NGOC HA T. NGUYEN, et al.,
20

Case No. 11-CV-0506-LHK
STIPULATION AND REQUEST FOR
ORDER CHANGING TIME FOR
EXISTING CASE SCHEDULE
AS MODIFIED

Defendant.

21
22

Defendant Ngoc Ha T. Nguyen (“Defendant”) and Plaintiff Joe Hand Promotions, Inc.

23 (“Plaintiff”) respectfully submit this stipulated Request for Order Changing Time for Existing
24 Case Schedule.
25

1.

On October 13, 2011, this Court referred Defendant to the Federal Pro Bono

26 Project and appointed Sayuri K. Sharper as Counsel for Defendant. The appointment stayed the
27 case for four weeks.
28
Case No. 11-CV-0506 -LHK
STIPULATION AND REQUEST FOR ORDER CHANING TIME FOR EXISTING CASE SCHEDULE]

1

2.

In the Case Management Order issued on October 12, 2011 (Docket Item No. 31),

2 this Court gave the parties an additional 90 days to complete the ordered settlement conference,
3 reset the deadline to amend the pleadings to November 10, 2011, and encouraged the parties to
4 meet and confer to make any further modifications to the existing schedule and file a joint
5 proposed case schedule if necessary.
6

3.

The parties have scheduled a settlement conference with Magistrate Judge Grewal

7 for January 6, 2012.
8

4.

The parties have further agreed to the following proposed changes to the existing

9 schedule:
10

Fact Discovery Cutoff: February 10, 2012

11

Last Day to File Expert Witness Designations: February 17, 2012

12

Expert Discovery Cutoff: March 9, 2012

13

Last Day to File Dispositive Motions: March 16, 2012

14

Pretrial Conference Date: To be determined by the Court

15

Court Trial Date: To be determined by the Court

16

5.

The enlargement of time is necessary and reasonable to give the parties enough

17 time to complete fact and expert discoveries if the parties are unable to settle on or prior to January
18 6, 2012, when the settlement conference is scheduled to be completed.
19

6.

In its first Case Management Order (Docket Item No. 17), the Court ordered the

20 parties to complete a settlement conference by October 26, 2011. In a subsequent Case
21 Management Order, the Court gave the parties an additional 90 days to comply with the order.
22 The Court and the parties have not made any other modifications to the existing schedule.
23

7.

The requested changes will delay the trial date, which is currently set for March 30,

8.

The parties respectfully request that this Court change the existing case schedule in

24 2012.
25

26 accordance with the proposal above.
27
28
Case No. 11-CV-0506 -LHK
-2STIPULATION AND REQUEST FOR ORDER CHANING TIME FOR EXISTING CASE SCHEDULE

1
DATED: November 17, 2011

2

PRO BONO PROJECT SILICON VALLEY

3
By:

4
5
6

DATED: November 17, 2011

/s/
Sayuri K. Sharper
Attorney for Defendant

LAW OFFICES OF THOMAS P. RILEY, P.C.

7
8

By:

9

/s/
Thomas P. Riley
Attorney for Plaintiff

10
11
ORDER
12
13

Pursuant to the above stated stipulation by the parties, the existing schedule is modified as
follows:

14

Fact Discovery Cutoff: February 10, 2012

15

Last Day to File Expert Witness Designations: February 17, 2012

16

Expert Discovery Cutoff: March 9, 2012

17
Last Day to File Dispositive Motions: March 15, 2012

18
19

Last Day to Hear Dispositive Motions: April 19, 2012, at 1:30 p.m.

20

May 30, 2012, at 2:00
Pretrial Conference Date: __________________ p.m.

21

June 18, 2012, at 9:00 a.m.
Court Trial Date: _____________________

22

PURSUANT TO STIPULATION, IT IS SO ORDERED.

23

25S DISTRICT
E
C
AT
T
26

THE HONORABLE LUCY H. KOH

RT

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ucy H.

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United States District Court Judge

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Judge L

____________________________________

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UNIT
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Dated: November 17, 2011
______________________
RT
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Case No. 11-CV-0506 -LHK
-3STIPULATION AND REQUEST FOR ORDER CHANING TIME FOR EXISTING CASE SCHEDULE