Skillnet Solutions, Inc-v-Entertainment Publications, LLC

Filing 33

SECOND STIPULATION TO CONTINUE DISCLOSURES, SECOND STATUS CONFERENCE DATE AND MOTION TO DISMISS OR CHANGE VENUE; ORDER THEREON, re 32 Stipulation filed by Skillnet Solutions, Inc. 12/13/2011 Motion to Dismiss continued to 1/31/2012 at 10:00 a.m. i n Courtroom 5, 4th Floor, San Jose before Magistrate Judge Paul Singh Grewal. 12/13/2011 Case Management Conference continued to 2/21/2012 at 02:00 p.m. in Courtroom 5, 4th Floor, San Jose. Signed by Judge Paul S. Grewal on 12/8/2011. (ofr, COURT STAFF) (Filed on 12/8/2011)

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BRIAN IRION, ESQ. (SBN #119865)
LAW OFFICES OF BRIAN IRION
611 Veterans Blvd., #209
Redwood City, CA 94063
Tel: [phone]
Fax: [phone]
Email: [e-mail]

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Attorneys for Plaintiff Skillnet Solutions, Inc.

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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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SKILLNET SOLUTIONS, INC., a California
corporation,

CASE NO. CV11-04865 PSG
SECOND STIPULATION TO CONTINUE
DISCLOSURES, SECOND STATUS
CONFERENCE DATE AND MOTION TO
DISMISS OR CHANGE VENUE

Plaintiff,
v.
ENTERTAINMENT PUBLICATIONS, LLC, a
Delaware LLC, and Does 1-10,

[Proposed] ORDER THEREON

Defendants

Date: December 13, 2011
Time: 9:00 a.m.
Place: Dept. 5, 4th Floor
Before: Hon. Paul S. Grewal

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RECITALS
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1.

On August 29, 2011, Plaintiff, SKILLNET SOLUTIONS, INC. (hereinafter referred to as

“Skillnet”) commenced an action against Defendant, ENTERTAINMENT PUBLICATIONS, LLC,
(hereinafter referred to as EP) by filing a complaint in the Superior Court of California, County of Santa
Clara, entitled SKILLNET SOLUTIONS, INC. v. ENTERTAINMENT PUBLICATIONS, LLC, Case
No. 111CV208126. The Complaint seeks relief for breach of contract in the amount of $2,484.458.00
plus ancillary damages and costs.
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Second Stipulation to Continue AND Proposed Order
CV11-04865 PSG

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2.

Defendant EP removed this action to this Court on September 30, 2011.

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3.

The parties through their respective counsel have met and conferred and believe, after

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having consulted with their respective clients that the parties would benefit from an attempt to resolve

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the matter in the early stages of the litigation before substantial additional time, costs and fees are

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incurred and before further judicial resources are devoted to this case.

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4.

The parties had an initial full-day mediation session with Linda DeBene, Esq. of JAMS

on November 16, 2011. At the conclusion of the meeting, the parties agreed that in order to further
mediation efforts but without expending the full resources of disclosure, discovery, and continued
judicial involvement, it would be best to exchange additional information and continue the mediation
session. At this point, the next available date for the parties, counsel and mediator is January 24, 2012.
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EP’s motion to dismiss or in the alternative change venue is currently scheduled to be

heard on December 13, 2011, to be immediately followed by a case status conference. Additionally,
under applicable rules of the Federal Rules of Civil Procedure, the parties would be required to make

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disclosures and reports required under Rule 26 of the Federal Rules of Civil Procedure and local rule 16
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before a second mediation session could occur.
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STIPULATION

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It is hereby stipulated that:
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2012 at 10:00 a.m. to permit the parties additional time to attempt to resolve this dispute

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through mediation.

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EP’s Motion to Dismiss or in the alternative change venue is rescheduled to January 31,

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In the event EP’s motion is not granted, the Initial Case Management Conference is

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rescheduled for February 21, 2012 in Courtroom 5, 4th Floor, San Jose at 2:00 p.m. The

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parties shall submit a Joint Case Management Conference Statement no later than

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February 14, 2012.

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3.

The last day to meet and confer regarding initial disclosures and discovery plans and file

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the ADR Process documents under FRCP 26(f), ADR LR 3-5, Civil LR 16-8 (b) and (c)

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is hereby extended to February 7, 2012.
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Second Stipulation to Continue AND Proposed Order
CV11-04865 PSG

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4.

The last day for each party to file the Rule 26(f) Report, complete initial disclosure or

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state objections in Rule 26(f) and file the Case Management Statement is extended to

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February 14, 2012.

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IT IS SO STIPULATED

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Dated: December 7, 2011

Law Offices of Brian Irion
By

/s/
Brian Irion
Attorney for Skillnet Solutions, Inc.

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Dated: December 7, 2011

Berliner Cohen

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By

/s/
Christine Long
Attorneys for Entertainment Publications, Inc.

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In Accordance with Local Rule 7-12 PURSUANT TO THE ABOVE STIPULATION, IT IS SO
ORDERED.

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Dated:

_________________________
Hon. Paul S. Grewal, Magistrate Judge
United States District Court for the
Northern District of California

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Second Stipulation to Continue AND Proposed Order
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