Gordon v. Virtumundo Inc et al

Filing 49

STIPULATION AND PROPOSED ORDER MODIFYING DISCOVERY CUTOFF AND OTHER DATES by parties. (Attachments: # 1 Certificate of Service)(Townsend, Roger)

Case 2:06-cv-00204-JCC

Document 49

Filed 11/20/2006

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THE HONORABLE JOHN C. COUGHENOUR

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE JAMES S. GORDON, Jr., a married individual, d/b/a `GORDONWORKS.COM'; OMNI INNOVATIONS, LLC., a Washington limited liability company; Plaintiffs, v. VIRTUMUNDO, INC, a Delaware corporation d/b/a ADNOWLEDGEMAIL.COM; ADKNOWLEDGE, INC., a Delaware corporation, d/b/a ADKNOWLEDGEMAIL.COM; SCOTT LYNN, an individual; and JOHN DOES, 1-X, Defendants.
STIPULATION WHEREAS, pursuant to Fed. R. Civ. P. 16(f), the last court day to complete discovery and file and serve motions to compel discovery is December 15, 2006.

No. CV06-0204JCC
STIPULATION AND [PROPOSED] ORDER MODIFYING DISCOVERY CUTOFF AND OTHER DATES

STIPULATION AND [PROPOSED] ORDER MODIFYING DISCOVERY CUTOFF AND OTHER DATES

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NEWMAN & NEWMAN, ATTORNEYS AT LAW, LLP 505 Fifth Avenue South, Suite 610 98104 Seattle, Washington 98150 - 2800 phone: [phone] fax: [phone]

Case 2:06-cv-00204-JCC

Document 49

Filed 11/20/2006

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WHEREAS, pursuant to the Court's June 13, 2006 order (Dkt. #27), the dispositive motions filing deadline is December 22, 2006. WHEREAS, the parties have met and conferred in good faith regarding scheduling depositions in this case. As a result of the holiday season and the diverse locations of the deponents, the parties have been unable to find mutually convenient dates to conduct depositions of fact witnesses in this case on or prior to December 15, 2006. WHEREAS, the parties respectfully request that the Court modify the June 13, 2006 scheduling order (Dkt. #27) to extend certain dates as follows: Extend the deadline for the parties to depose fact witnesses thirty (30) days to January 15, 2006; and Extend the general dispositive motions filing deadline provided in Dkt. #27 thirty (30) days to January 22, 2006. WHEREAS, the parties agree that all other dates, including the court-ordered deadline for Plaintiffs' motion for summary judgment (see Dkt. #46), shall remain unmodified.
20th DATED this _____ day of November, 2006.

NEWMAN & NEWMAN, LLP Attorneys for Defendants

MERKLE SIEGEL & FRIEDRICHSEN, P.C. Attorneys for Plaintiffs /s/ Robert Siegel with authorization

By Derek A. Newman, WSBA # 26967 Roger M. Townsend, WSBA # 25525 // // ///

By Robert J. Siegel WSBA# 17312

STIPULATION AND [PROPOSED] ORDER MODIFYING DISCOVERY CUTOFF AND OTHER DATES

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NEWMAN & NEWMAN, ATTORNEYS AT LAW, LLP 505 Fifth Avenue South, Suite 610 98104 Seattle, Washington 98150 - 2800 phone: [phone] fax: [phone]

Case 2:06-cv-00204-JCC

Document 49

Filed 11/20/2006

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 THE HONORABLE JOHN C. COUGHENOUR UNITED STATES DISTRICT JUDGE 1. ORDER Pursuant to stipulation of counsel, it is hereby ORDERED, as follows: The deadline for the parties to depose fact witnesses is extended thirty (30) days

to January 15, 2006; 2. The general motions filing deadline provided in Dkt. #27 is extended thirty (30)

days to January 22, 2006. All other dates and schedules, including but not limited to those set forth in the Court's Minute Order (Dkt. #46), shall remain unmodified. DATED this ____ day of _________, 2006.

STIPULATION AND [PROPOSED] ORDER MODIFYING DISCOVERY CUTOFF AND OTHER DATES

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NEWMAN & NEWMAN, ATTORNEYS AT LAW, LLP 505 Fifth Avenue South, Suite 610 Seattle, Washington 98104 98150 2800 phone: [phone] fax: [phone]