Opinion
CASE NO. 11-cv-01817 SC
11-14-2011
GUARDS POLO CLUB HOLDINGS LTD., Plaintiff, v. MEGAN GOODMAN REID, MICHAEL KOSKIE (a/k/a MICHAEL MCGREGOR), AND JOHN/JANE DOES 1-20 Defendants.
CONNON WOOD SCHEIDEMANTLE LLP NICHOLAS P. CONNON By: NICHOLAS P. CONNON Attorneys for Plaintiff Guards Polo Club Holdings Ltd. FREUND & BRACKEY THOMAS A. BRACKEY II CRAIG A. HUBER By: THOMAS A. BRACKEY II Attorney for Defendant Margaret Goodman Reid
CONNON WOOD SCHEIDEMANTLE LLP
NICHOLAS P. CONNON, State Bar No. 150815
ROBERT A. de BY, admitted Pro Hac Vice
EDWARD S. PAK, State Bar No. 271853
Attorneys for Plaintiff Guards Polo Club Holdings Ltd.
FREUND & BRACKEY LLP
THOMAS A. BRACKEY II, State Bar No. 162279
CRAIG A. HUBER, State Bar No. 159763
STEPHEN P. CRUMP, State Bar No. 251712
Attorneys for Defendant Margaret Goodman Reid
[Assigned to the Honorable Samuel Conti]
JOINT STIPULATION TO STAY AND CONTINUE THE PRE-TRIAL SCHEDULE & FOR A NEW TRIAL
DATE IN ORDER TO ATTEMPT TO FINALIZE A SETTLEMENT
JUDGE: Hon. Samuel Conti
Plaintiff Guards Polo Club Holdings Ltd. ("Plaintiff") and Defendant Megan Goodman Reid ("Defendant") hereby enter into this Stipulation and request that the Court set a new date for trial, presently set for May 31, 2012 at 9:30 a.m., on a date at the end of September 2012 and to stay and continue the Pre-Trial Schedule set forth in the Court's Status Conference Order, dated August 26, 2011, accordingly. This request is being made because the parties participated in a full day mediation on October 18, 2011, as a result of which they are currently in serious and advanced discussions to resolve the case. Specifically, Defendant Reid needs 60 days to explore certain financial arrangements related to any settlement. Further, the parties anticipate that they may need an additional 60 days to finalize any settlement reached and to allow Defendant Reid to secure financing that will permit her to consummate the terms of any settlement.
The parties would like to devote their full energies towards resolving this case since they believe the prospects of resolution are good and such a stay and continuance will avoid the parties incurring legal fees that could be driven by pending deadlines. Moreover, while the parties are focused on resolution of this entire matter, they believe it is preferable to avoid serving the Doe 1 defendant, and request is therefore also made to extend the time to effectuate service on the Doe 1 defendant.
THEREFORE, BASED UPON THE FOREGOING, PLAINTIFF AND DEFENDANT DO HEREBY STIPULATE AS FOLLOWS AND REQUEST THE COURT ENTER AN ORDER CONSISTENT WITH THE FOLLOWING:
1. The trial date be continued to September 24, 2012, or on such date and at such time as is convenient for the Court thereafter, and the pre-trial schedule set forth in the Status Conference Order be continued such that each date mentioned there is reset to the equivalent day four months later than mentioned in the Status Conference Order.
2. The date by which Plaintiff must effectuate service on the Doe 1 defendant be extended from December 29, 2011 to February 1, 2012.
CONNON WOOD SCHEIDEMANTLE LLP
NICHOLAS P. CONNON
By: NICHOLAS P. CONNON
Attorneys for Plaintiff Guards Polo Club Holdings
Ltd.
FREUND & BRACKEY LLP
THOMAS A. BRACKEY II
CRAIG A. HUBER
By: THOMAS A. BRACKEY II
Attorney for Defendant Margaret Goodman Reid
CONNON WOOD SCHEIDEMANTLE LLP
NICHOLAS P. CONNON, State Bar No. 150815
ROBERT A. de BY, admitted Pro Hac Vice
EDWARD S. PAK, State Bar No. 271853
Attorneys for Plaintiff Guards Polo Club Holdings Ltd.
FREUND & BRACKEY LLP
THOMAS A. BRACKEY II, State Bar No. 162279
CRAIG A. HUBER, State Bar No. 159763
STEPHEN P. CRUMP, State Bar No. 251712
Attorneys for Defendant Margaret Goodman Reid
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION
GUARDS POLO CLUB HOLDINGS LTD., Plaintiff,
vs.
MEGAN GOODMAN REID, MICHAEL KOSKIE (a/k/a MICHAEL MCGREGOR), AND JOHN/JANE DOES 1-20 Defendants.
CASE NO. 11-cv-01817 SC
[ Assigned to the Honorable Samuel Conti]
[PROPOSED] ORDER FOR A STAY AND CONTINUANCE OF THE PRE-TRIAL
SCHEDULE & FOR A NEW TRIAL DATE
JUDGE: Hon. Samuel Conti
The parties to the above-entitled action having agreed to a new date for trial currently set for May 31, 2012 at 9:30 a.m., and to stay and continue the pre-trial schedule as described in the Status Conference Order, dated August 26, 2011.
PURSUANT TO STIPULATION, IT IS ORDERED that the new trial date is set for September 24, 2012 at 9:30 a.m., before the Honorable Judge Samuel Conti and that the pre-trial schedule and dates contained in the Status Conference Order are each continued for a period of 120 days from the dates set forth therein. Further, Defendant shall have until February 1, 2012 to serve the Doe 1 defendant.