Allegro Consultants, Inc. v. Wellington Technologies, Inc. et al

Filing 67

ORDER APPROVING 66 STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND CHANGE MOTION HEARING DATE. Motion Hearing set for 12/18/2014 09:00 AM in Courtroom 3, 5th Floor, San Jose before Hon. Beth Labson Freeman. Case Management Conference set for 12/18/2014 01:30 PM in Courtroom 3, 5th Floor, San Jose. Case Management Statement due by 12/11/2014. (blflc1, COURT STAFF) (Filed on 11/5/2014)

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Nick Heimlich (SBN 233232)
Law Offices of Nicholas D. Heimlich
900 Lafayette Street, Suite 509
Santa Clara, CA 95050
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Plaintiff,
ALLEGRO CONSULTANTS, INC.
Nathan Benjamin (State Bar No. 197859)
Law Offices of Nathan Benjamin
340 Soquel Avenue, Suite 205
Santa Cruz, CA 95062
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Eric K. Grinnell (Ohio State Bar No. 0089393 – Appearing Pro Hac Vice)
Smith Marshall LLP
815 Superior Ave., East, Suite 1425
Cleveland, OH 44114
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendant,
JOSEPH J. JASKO

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION
ALLEGRO CONSULTANTS, INC., A
CALIFORNIA CORPORATION,

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Case No. 5:13-cv-02204

Plaintiff,
vs.
WELLINGTON TECHNOLOGIES,

STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE AND TO
CHANGE MOTION HEARING DATE AND
PROPOSED ORDER

INC., an Ohio Corporation, ED

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STIPULATION TO CONTINUE CASE MANAGEMENT
CONFERENCE AND TO CHANGE MOTION HEARING
DATE AND PROPOSED ORDER

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GRIGLAK, an individual, JOSPEH J.

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JASKO, an individual AND DOES 1-

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100, INCLUSIVE;

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Defendants.

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Now come Plaintiff Allegro Consultants, Inc. (“Allegro” or “Plaintiff”) and Defendant

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Joseph J. Jasko (“Jasko”) through their attorneys, and hereby stipulate to both continuing the

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Case Management Conference that is currently scheduled for November 6, 2014 at 1:30 pm, and

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moving up the Motion Hearing that is currently scheduled for March 26, 2015 at 9:00 am. If it is

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in the best interests of the court, Plaintiff and Jasko are agreeable to having both the Case

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Management Conference and the Motion Hearing on the same date.

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Defendant Jasko currently has a 12(b)(6) Motion to Dismiss before the court. Plaintiff’s

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Response to Jasko’s 12(b)(6) Motion is due on November 6, 2014, and Jasko’s Reply is due on

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November 13, 2014. Thus, it would be in the best interests of all parties, and the court, to delay

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the Case Management Conference until the briefing schedule is completed, and the 12(b)(6)

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Motion has been ruled upon.

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Accordingly, Plaintiff and Defendant Jasko respectfully request that the Case

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Management Conference be continued, and the Motion Hearing date moved up, to a time

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convenient to the court in the next four to six weeks.

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Dated: November 4, 2014
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_/s/ Nathan Benjamin__ ___
Nathan Benjamin
Attorney for Defendant Joseph Jasko

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STIPULATION TO CONTINUE CASE MANAGEMENT
CONFERENCE AND TO CHANGE MOTION HEARING
DATE AND PROPOSED ORDER

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Dated: November 4, 2014

_/s/ Eric K. Grinnell
__
Eric K. Grinnell
Attorney for Defendant Joseph Jasko

Dated: November 4, 2014

_/s/ Nick Heimlich_______
Nick Heimlich
Attorney for Plaintiff

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STIPULATION TO CONTINUE CASE MANAGEMENT
CONFERENCE AND TO CHANGE MOTION HEARING
DATE AND PROPOSED ORDER

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[PROPOSED] ORDER
The Court hereby finds good cause and orders that the Case Management Conference be

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continued to ____________, __________ at _______, and that the Motion Hearing date be

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changed to _____________, __________ at _______.

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IT IS SO ORDERED.

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Dated: _____________, 2014.

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__________________________
BETH LABSON FREEMAN
United States District Judge

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STIPULATION TO CONTINUE CASE MANAGEMENT
CONFERENCE AND TO CHANGE MOTION HEARING
DATE AND PROPOSED ORDER