Guzik Technical Enterprises, Inc. v. Western Digital Corporation et al

Filing 58

STIPULATION AND ORDER re 54 Stipulation, filed by Western Digital (Fremont) Inc, Western Digital (Malaysia) SDN.BHD., Western Digital Technologies, Inc., Western Digital (Thailand) Company Limited, Western Digital Corporation. Signed by Judge Paul S. Grewal on 12/20/2011. (psglc2, COURT STAFF) (Filed on 12/21/2011)

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STEVEN M. BAUER, Bar No. 135067
[e-mail]
JAMES L. DAY, Bar No. 197158
[e-mail]
SVETLANA M. BERMAN, Bar No. 239445
[e-mail]
MOHITH R. JULAPALLI, Bar No. 268240
[e-mail]
LATHAM & WATKINS LLP
505 Montgomery Street, Suite 2000
San Francisco, CA 94111-6538
Telephone: [phone]
Facsimile: [phone]

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RICHARD G. FRENKEL, Bar No. 204133
[e-mail]
LATHAM & WATKINS LLP
140 Scott Drive
Menlo Park, CA 94025
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendants and Counterclaim Plaintiffs

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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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GUZIK TECHNICAL ENTERPRISES, INC.

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Plaintiff and Counterclaim Defendant,
v.
WESTERN DIGITAL CORPORATION,
WESTERN DIGITAL TECHNOLOGIES, INC.,
and WESTERN DIGITAL (FREMONT) INC.,

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STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME FOR
FILING OF STIPULATED
PROTECTIVE ORDER OR MOTIONS
FOR PROTECTIVE ORDER

Defendants and Counterclaim Plaintiffs, and

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CASE NO. 5:11-CV-03786-PSG

WESTERN DIGITAL (THAILAND) COMPANY
LIMITED and WESTERN DIGITAL
(MALAYSIA) SDN.BHD,

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Defendants.

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ATTORNEYS AT LAW
SAN FRANCISCO

STIPULATION AND [PROPOSED] ORDER EXTENDING TIME
FOR FILING OF STIPULATED PROTECTIVE ORDER
5:11-CV-03786-PSG

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Plaintiff Guzik Technical Enterprises, Inc. (“GTE”) and Defendants Western Digital

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Corporation, Western Digital Technologies, Inc., Western Digital (Fremont), LLC, Western

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Digital (Thailand) Company Limited, and Western Digital (Malaysia) Sdn.Bhn. (collectively,

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“Western Digital”) hereby stipulate through their respective counsel of record as follows:

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WHEREAS, on August 1, 2011, GTE filed its Complaint against Western Digital;

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WHEREAS, on August 1, 2011, the Court issued an Order Setting Initial Case

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Management Conference and ADR Deadlines (Dkt. No. 8) setting an Initial Case Management

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Conference in this matter on October 18, 2011;

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WHEREAS, the Court ordered, pursuant to the Parties’ stipulation, that Western Digital

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would have until September 26, 2011 to file a response to the complaint and that the Initial Case

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Management Conference be continued from October 18, 2011 to November 15, 2011 that all

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other associated dates would be continued (Dkt. No. 13);

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WHEREAS, the Court ordered, pursuant to the Parties’ stipulation, that GTE would have

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until November 16, 2011 to file a response to Western Digital’s Counterclaims and that the

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Initial Case Management Conference be continued from November 15, 2011 to December 13,

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2011 and that all other associated dates would be continued (Dkt. No. 34);

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WHEREAS, the Court ordered, pursuant to the Parties’ stipulation, that the Initial Case

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Management Conference be continued from December 13, 2011 to December 16, 2011, but that

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all other dates would be unchanged (Dkt. No. 53);

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WHEREAS, on December 6, 2011, Western Digital and GTE filed a Joint Case

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Management Statement and [Proposed] Order (Dkt. No. 50), which included a deadline of

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December 20, 2011 for filing a proposed protective order or motion for protective order to

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govern confidential material in this case;

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WHEREAS, the parties have diligently discussed and negotiated the terms of a stipulated
protective order, but have not yet reached agreement on all terms;
WHEREAS, Western Digital and GTE believe that outstanding issues concerning the

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terms of a stipulated protective order can be resolved or substantially narrowed given additional

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time to meet and confer;

ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME
FOR FILING OF STIPULATED PROTECTIVE ORDER
5:11-CV-03786-PSG

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WHEREAS, Western Digital and GTE have agreed, subject to the Court’s approval, to

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extend the deadline for submitting a stipulated protective order or motion for protective order

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until and including January 13, 2012;

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WHEREAS, the parties’ undersigned counsel confirm that the requested time

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modification would have no material impact on the case schedule because the case is at its initial

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stage:

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IT IS HEREBY STIPULATED by and between the parties hereto through their
respective attorneys of record that:

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The time for filing a stipulated protective order or motion for protective order to govern

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confidential material in this matter will be extended from December 20, 2011 to January 13,

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2012.

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Dated: December 19, 2011

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LATHAM & WATKINS, LLP
By: /s/ James L. Day
James L. Day
Attorneys for Defendants/Counterclaim Plaintiffs
Western Digital Corporation et al.

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In accordance with General Order No. 45, Rule X, the above signatory attests that
concurrence in the filing of this document has been obtained from the signatory below.

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Dated: December 19, 2011

BERGESON, LLP
By: _/s/ Melinda M. Morton________
Melinda M. Morton
Attorneys for Plaintiff/Counterclaim Defendant
Guzik Technical Enterprises, Inc.

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ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME
FOR FILING OF STIPULATED PROTECTIVE ORDER
5:11-CV-03786-PSG

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: _December 20_, 2011

HON. PAUL SINGH GREWAL
UNITED STATES MAGISTRATE JUDGE

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ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME
FOR FILING OF STIPULATED PROTECTIVE ORDER
5:11-CV-03786-PSG