Opinion
Case No. 11-CV-0506-LHK
11-17-2011
JOE HAND PROMOTIONS, INC., Plaintiff, v. NGOC HA T. NGUYEN, et al., Defendant.
Sayuri K. Sharper (Bar No. 232331) PRO BONO PROJECT SILICON VALLEY Attorney for Defendant Ngoc Ha T. Nguyen Thomas P. Riley (Bar No. 194706) LAW OFFICES OF THOMAS P. RILEY, PC. Attorneys for Plaintiff Joe Hand Promotions, Inc.
Sayuri K. Sharper (Bar No. 232331)
PRO BONO PROJECT SILICON VALLEY
Attorney for Defendant Ngoc Ha T. Nguyen
Thomas P. Riley (Bar No. 194706)
LAW OFFICES OF THOMAS P. RILEY, PC.
Attorneys for Plaintiff Joe Hand Promotions, Inc.
STIPULATION AND REQUEST FOR
ORDER CHANGING TIME FOR
EXISTING CASE SCHEDULE
AS MODIFIED
Defendant Ngoc Ha T. Nguyen ("Defendant") and Plaintiff Joe Hand Promotions, Inc. ("Plaintiff") respectfully submit this stipulated Request for Order Changing Time for Existing Case Schedule.
1. On October 13, 2011, this Court referred Defendant to the Federal Pro Bono Project and appointed Sayuri K. Sharper as Counsel for Defendant. The appointment stayed the case for four weeks.
2. In the Case Management Order issued on October 12, 2011 (Docket Item No. 31), this Court gave the parties an additional 90 days to complete the ordered settlement conference, reset the deadline to amend the pleadings to November 10, 2011, and encouraged the parties to meet and confer to make any further modifications to the existing schedule and file a joint proposed case schedule if necessary.
3. The parties have scheduled a settlement conference with Magistrate Judge Grewal for January 6, 2012.
4. The parties have further agreed to the following proposed changes to the existing schedule:
Fact Discovery Cutoff: February 10, 2012
Last Day to File Expert Witness Designations: February 17, 2012
Expert Discovery Cutoff: March 9, 2012
Last Day to File Dispositive Motions: March 16, 2012
Pretrial Conference Date: To be determined by the Court
Court Trial Date: To be determined by the Court
5. The enlargement of time is necessary and reasonable to give the parties enough time to complete fact and expert discoveries if the parties are unable to settle on or prior to January 6, 2012, when the settlement conference is scheduled to be completed.
6. In its first Case Management Order (Docket Item No. 17), the Court ordered the parties to complete a settlement conference by October 26, 2011. In a subsequent Case Management Order, the Court gave the parties an additional 90 days to comply with the order. The Court and the parties have not made any other modifications to the existing schedule.
7. The requested changes will delay the trial date, which is currently set for March 30, 2012.
8. The parties respectfully request that this Court change the existing case schedule in accordance with the proposal above.
PRO BONO PROJECT SILICON VALLEY
Sayuri K. Sharper
Attorney for Defendant
LAW OFFICES OF THOMAS P. RILEY, PC.
Thomas P. Riley
Attorney for Plaintiff
ORDER
Pursuant to the above stated stipulation by the parties, the existing schedule is modified as follows:
Fact Discovery Cutoff: February 10, 2012
Last Day to File Expert Witness Designations: February 17, 2012
Expert Discovery Cutoff: March 9, 2012
Last Day to File Dispositive Motions: March 15, 2012
Last Day to Hear Dispositive Motions: April 19, 2012, at 1:30 p.m.
Pretrial Conference Date: May 30, 2012, at 2:00 p.m.
Court Trial Date: June 18, 2012, at 9:00 am.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
THE HONORABLE LUCY H. KOH
United States District Court Judge