Gordon v. Virtumundo Inc et al

Filing 52

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

Case 2:06-cv-00204-JCC

Document 52

Filed 12/15/2006

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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 CUTOFF FOR DISCOVERY MOTIONS

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 981504 9810 phone: [phone] fax: [phone]

Case 2:06-cv-00204-JCC

Document 52

Filed 12/15/2006

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WHEREAS, the parties have met and conferred pursuant to Fed. R. Civ. P. 37 regarding Defendants' allegations that Plaintiffs have (i) failed to respond in full to "Defendant Scott Lynn's First Set Of Interrogatories And Requests For Production Of Documents To Plaintiffs Omni Innovations, LLC., and Plaintiff Gordon" (the "Lynn Requests"); and (ii) that Plaintiffs' prior production of documents, specifically the emails at issue in this lawsuit, is deficient. WHEREAS, the parties have agreed to extend the time for Plaintiffs to respond to the Lynn Requests to Wednesday, December 20, 2006 at 5:00 pm. WHEREAS, the parties have agreed to extend by one (1) week to December 22, 2006 Defendants' deadline for filing discovery motions for relief related to (i) Plaintiffs' responses, or lack thereof, to the Lynn Requests; and (ii) the form and contents of Plaintiffs' prior production of documents. DATED this 15th day of December, 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 Seattle, Washington 98104 98150 phone: [phone] fax: [phone]

Case 2:06-cv-00204-JCC

Document 52

Filed 12/15/2006

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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: Plaintiffs' deadline for providing its discovery responses is extended five (5)

calendar days to December 20, 2006 at 5:00 p.m. 2. Defendants' deadline for filing discovery motions related to the Lynn Requests,

and Plaintiffs' prior document production of the emails in this lawsuit is extended seven (7) calendar days to December 22, 2006; All other dates and schedules 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 981504 9810 phone: [phone] fax: [phone]