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IO Group, Inc. v. Veoh Networks, Inc. Doc.

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Case 5:06-cv-03926-HRL Document 64 Filed 04/18/2007 Page 1 of 4

1 GILL SPERLEIN (172887)


THE LAW FIRM OF GILL SPERLEIN
2
584 Castro Street, Suite 849
3 San Francisco, California 94114
Telephone: (415) 487-1211 X32
4 Facsimile: (415) 252-7747
5
legal@titanmedia.com

6 Attorney for Plaintiff


IO GROUP, INC.
7

9
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
10 SAN JOSE DIVISION
11 )
) CASE NO. C-06-3926 (HRL)
12
)
IO GROUP, INC., a California corporation, )
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) STIPULATION AND [PROPOSED]
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Plaintiff, ) ORDER TO EXTEND DISCOVERY
) CUT-OFF DATES
15
vs. )
16 )
)
17 VEOH NETWORKS, Inc, a California )
Corporation, )
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)
Defendant. )
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)
20 )
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Pursuant to Civil Local Rule 6-2, Plaintiff Io Group, Inc. and Defendant Veoh Networks,
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Inc., hereby stipulate to extend certain discovery cutoff dates.
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Plaintiff requested that Defendant stipulate to an extension of time because Plaintiff
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believes that it needs additional discovery and that the current discovery schedule does not allow
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enough time. Defendant has agreed to a thirty-day extension of currently scheduled deadlines as
26 set forth below.
27 Although this case was originally filed on June 6, 2006, there was a dormant period during
28 which the Court considered Plaintiff’s Motion to Relate the matter to two later-filed cases. Upon

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STIPULATION AND PROPOSED ORDER
C-06-3926 (HRL)

Dockets.Justia.com
Case 5:06-cv-03926-HRL Document 64 Filed 04/18/2007 Page 2 of 4

1 ordering the matters related, the Court significantly postponed the initial case management
2 conference in order that it be held in conjunction with the later-filed, related cases.
3 Previously, stipulations and orders resulted in the following time modifications.

4 On August 10, 2006 the parties stipulated and the Court ordered that Defendant have until

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September 25, 2006 to file a pleading responsive to the Complaint and that the initial Case
Management Conference set for September 26, 2006 be reset for October 17, 2006.
6
On September 13, 2006, the parties stipulated and the Court subsequently ordered that
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Defendant’s Response to Plaintiff’s Motion to Relate would be due on September 25, 2006.
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On September 21, 2006 the parties stipulated and the Court subsequently ordered that the
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Court not rule on Plaintiff’s Motion to Relate until October 19, 2006 so that all parties had
10
sufficient time to respond. The Stipulation and Order also took the Case Management Conference
11 off calendar until after the Court ruled on the Motion to Relate.
12 Upon ordering the cases related on October 25, 2006, the Court set the Initial Case
13 Management Conference for all related cases for December 5, 2006.

14 Subsequently, Defense requested, Plaintiff stipulated, and the Court ordered, that the date

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for exchanging initial disclosures be extended from the Court’s original December 15, 2006
deadline to January 16, 2007.
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This stipulation and proposed order if issued, would effect the discovery dates set by the
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Court at the December 5, 2006 Case Management Conference. Moreover, other dates such as the

19 deadline for hearing dispositive motions may also need to be extended.


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WHEREAS the Court previously set April 30, 2007 as the deadline for fact discovery;
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WHEREAS the Court previously set June 22, 2007 as the deadline for expert discovery;
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WHEREAS the Court indicated at the Case Management Conference that extensions
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24 would be granted if reasonably necessary.

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26 The parties do therefore stipulate and agree as follows:


27 1. To extend fact discovery cutoff until May 30, 2007;

28
2. To extend the Designation of Experts deadline until June 8, 2007;
3. To Extend the Designation of Rebuttal Experts until June 22, 2007;

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STIPULATION AND PROPOSED ORDER
C-06-3926 (HRL)
Case 5:06-cv-03926-HRL Document 64 Filed 04/18/2007 Page 3 of 4

1 4. To extend expert discovery cutoff until July 22, 2007; and


2 5. That the Court recalendar any other dates as appropriate.
3

4 SO STIPULATED.
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7 Dated: 4/18/2007 /s/ Gill Sperlein


8
Gill Sperlein
THE LAW FIRM OF GILL SPERLEIN
9 Attorney’s for Plaintiff
10

11

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13 Dated: 4/18/2007 /s/ Jennifer A. Golinveaux


Jennifer A. Golinveaux
14 WINSTON & STRAWN, LLP
15
Attorney’s for Defendant

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I hereby attest that concurrence in the filing of the document has been obtained from each
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of the other signatories.
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22 Dated: 4/18/2007 /s/ Gill Sperlein


Gill Sperlein
23
THE LAW FIRM OF GILL SPERLEIN
24 Attorney’s for Plaintiff

25

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27

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STIPULATION AND PROPOSED ORDER
C-06-3926 (HRL)
Case 5:06-cv-03926-HRL Document 64 Filed 04/18/2007 Page 4 of 4

4 [PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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Dated:
9 HONORABLE HOWARD R. LLOYD
UNITED STATES MAGISTRATE JUDGE
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STIPULATION AND PROPOSED ORDER
C-06-3926 (HRL)

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