InCorp Services, Inc v. Does 1-10, inclusive

Filing 75

Order Granting 74 Stipulation Continuing Discovery Deadlines. Signed by Hon. Edward J. Davila on 11/15/2012.(ecg, COURT STAFF) (Filed on 11/15/2012)

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KRONENBERGER ROSENFELD, LLP
Karl S. Kronenberger (CA Bar No. 226112)
Jeffrey M. Rosenfeld (CA Bar No. 222187)
150 Post Street, Suite 520
San Francisco, CA 94108
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff INCORP SERVICES, INC. and
Counter-Defendant TENNIE SEDLACEK

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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INCORP SERVICES, INC., a Nevada
corporation,
Plaintiff,

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XXXXXXXX
STIPULATION AND [PROPOSED]
ORDER CONTINUING DISCOVERY
DEADLINES

vs.

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INCSMART.BIZ, INC., a Nevada
corporation;
DAVID OLIVER, an individual;
MICHAEL LASALA, an individual; and
DOES 1-10, inclusive,
Defendants.
INCSMART.BIZ, INC., a Nevada
Corporation,

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Case No. 11-CV-4660-EJD-PSG

Counter-Claimant,
vs.

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INCORP SERVICES, INC., a Nevada
Corporation; TENNIE SEDLACEK, an
individual; JENNIFER L. REUTING, an
individual; and DOUG ANSELL, an
individual,
Counter-Defendants.

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Case No. 11-CV-4660-EJD-PSG

STIPULATION AND [PROP] ORDER
CONTINUING DISCOVERY DEADLINES

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TO THE CLERK OF THE COURT AND ALL PARTIES AND THEIR
ATTORNEYS OF RECORD HEREIN:

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Plaintiff Incorp Services, Inc. and Defendants Incsmart.biz, Inc., David Oliver, and

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Michael Lasala (individually, a “Party” and collectively, the “Parties”), by and through their

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counsel of record, hereby stipulate and agree as follows:

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WHEREAS, fact discovery is set to close on December 31, 2012;

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WHEREAS, the Parties have been diligently performing discovery since the

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opening of discovery;

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WHEREAS, the Parties have not yet completed fact discovery;

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WHEREAS, certain discovery disputes have arisen, which, despite the parties’
meet-and-confer efforts, will require Court intervention to resolve;

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WHEREAS, the Parties will incur significant expense in presenting these discovery
disputes to the Court;

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WHEREAS, the Parties are meeting-and-conferring about the Defendants’

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financial condition, Defendants’ ability to pay the sanctions set forth in the Court’s June 6,

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2012 order [D.E. No. 40], and the possibility of settlement;

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WHEREAS, the Parties believe that the interests of the Parties and the Court

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would best be served by continuing the discovery period so that the Parties can wait until

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after their settlement discussions to bring any discovery motions.

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NOW, THEREFORE, it is herby stipulated and agreed, by and among the Parties,
through their respective counsel, as follows:

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1.

The Parties agree that all discovery deadlines, as detailed in the Court’s

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case Management Order dated August 24, 2012 [D.E. No. 53], shall be continued for

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sixty (60) days, pursuant to the following schedule:

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//

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//

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//
Case No. 11-CV-4660-EJD-PSG

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STIPULATION AND [PROP] ORDER
CONTINUING DISCOVERY DEADLINES

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EVENT

DEADLINE

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Fact Discovery Cutoff

March 1, 2013

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Designation of Opening Experts with Reports

March 12, 2013

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Designation of Rebuttal Experts with Reports

April 2, 2013

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Expert Discovery Cutoff

April 16, 2013

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Deadline(s) for Filing Discovery Motions

See Civil Local Rule 37-3

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Deadline for Filing Dispositive Motions

April 30, 2013

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Preliminary Pretrial Conference

11:00 a.m. on February 8, 2013

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Joint Preliminary Pretrial Conference Statement

January 30, 2013

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IT IS SO STIPULATED.

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DATED: November 13, 2012

DATED: November 13, 2012

KRONENBERGER ROSENFELD, LLP

THE LAW OFFICES OF MICHAEL G.
ACKERMAN

By:

By:

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s/Jeffrey M. Rosenfeld
Jeffrey M. Rosenfeld

s/ Michael G. Ackerman
Michael G. Ackerman

Attorneys for Plaintiff Incorp Services, Inc. Attorney for Defendants Incsmart.biz, Inc.,
and Counter-Defendant Tennie Sedlacek
David Oliver, Michael Lasala, and Jo Ann
Oliver

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ATTESTATION OF CONCURRENCE IN FILING
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Pursuant to the General Order No. 45, section 45 X(B), for The United States
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District Court for the Northern District of California, I, Jeffrey M. Rosenfeld, hereby attest
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that the concurrence to the filing of this Stipulation and [Proposed] Order Continuing
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Discovery Deadlines has been obtained from Michael G. Ackerman, who has provided
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the conformed signature above.
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Case No. 11-CV-4660-EJD-PSG

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STIPULATION AND [PROP] ORDER
CONTINUING DISCOVERY DEADLINES

XXXXXXXX
[PROPOSED] ORDER

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IT IS HEREBY ORDERED that all discovery deadlines, as detailed in the Court’s

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case Management Order dated August 24, 2012, shall be continued for sixty (60) days,

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pursuant to the following schedule:

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EVENT

DEADLINE

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Fact Discovery Cutoff

March 1, 2013

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Designation of Opening Experts with Reports

March 12, 2013

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Designation of Rebuttal Experts with Reports

April 2, 2013

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Expert Discovery Cutoff

April 16, 2013

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Deadline(s) for Filing Discovery Motions

See Civil Local Rule 37-3

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Deadline for Filing Dispositive Motions

April 30, 2013

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Preliminary Pretrial Conference

11:00 a.m. on February 8, 2013

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Joint Preliminary Pretrial Conference Statement

January 30, 2013

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IT IS SO ORDERED.

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Dated: November 15 , 2012

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____________________________________

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United States District Court Judge

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Case No. 11-CV-4660-EJD-PSG

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STIPULATION AND [PROP] ORDER
CONTINUING DISCOVERY DEADLINES