Opinion
CASE NO. CV 09-01479 RS
10-26-2011
PERDANA CAPITAL (LABUAN) INC., a Malaysian Corporation, Plaintiff, v. MOHAMMAD AKRAM CHOWDRY, an Individual; HI-TECH VENTURE PARTNERS, LLC, a Delaware Limited Liability Company; HI-TECH ASSOCIATES, LLC, a California Limited Liability Company; and DOES 1-50, Defendants.
Michael Q. Eagan (CA #63479) LAW OFFICES OF MICHAEL Q. EAGAN THOMAS H. MANULKIN Attorneys for defendants Mohammad Akram Chowdry, Hi-Tech Venture Partners, LLC and Hi-Tech Associates, LLC KAUFMAN DOLOWICH VOLUCK & GONZO JOSEPH KOURI JOSEPH J. DE HOPE, JR. Attorneys for plaintiff Perdana Capital (Labaun), Inc.
Michael Q. Eagan (CA #63479)
Thomas H. Manulkin (CA #229630)
LAW OFFICES OF MICHAEL Q. EAGAN
Attorneys for Defendants
Assigned to Hon. Richard Seeborg
STIPULATION AND [PROPOSED]
ORDER REGARDING THE
DISCLOSURE AND DISCOVERY OF
EXPERT WITNESS OPINIONS
IT IS HEREBY AGREED AND STIPULATED by the parties hereto, by and through their respective attorneys that are authorized to enter into this stipulation, that section 3, titled "EXPERT WITNESSES," of the Case Management Scheduling Order dated March 7, 2011 shall be amended as follows for the following reasons:
WHEREAS, on June 28, 2011, the parties filed a joint letter with Magistrate Judge Spero raising a number of issues related to discovery in this case;
WHEREAS, on July 25, 2011 Magistrate Judge Cousins signed the parties' Stipulation and Order Regarding Discovery Disputes ("Order") to resolve the issues raised in the June 28, 2011 letter to Judge Spero;
WHEREAS, since the entry of the Order, the parties have been attempting to complete the discovery required under the Order;
WHEREAS, due to the delay in completing discovery the experts do not have all of the information they need to draft their respective expert opinions;
NOW, THEREFORE, IT IS HEREBY STIPULATED, AGREED AND RESPECTFULLY REQUESTED by the undersigned Parties, that section 3, titled "EXPERT WITNESSES," of the Case Management Scheduling Order dated March 7, 2011 shall be amended as follows:
3. EXPERT WITNESSES, The disclosure of expert witness opinions shall proceed as follows:
A. On or before January 10, 2012, plaintiff shall disclose expert testimony and reports in accordance with Federal Rule of Civil Procedure 26(a)(2).
B. On or before February 7, 2012, defendants shall disclose expert testimony and reports in accordance with Federal Rule of Civil Procedure 26(a)(2).
C. On or before March 20, 2012, all discovery of expert witnesses pursuant to Federal Rule of Civil Procedure 26(b)(4) shall be completed.
IT IS SO STIPULATED AND RESPECTFULLY REQUESTED.
Respectfully submitted,
LAW OFFICES OF MICHAEL Q. EAGAN
THOMAS H. MANULKIN
Attorneys for defendants Mohammad
Akram Chowdry, Hi-Tech Venture Partners,
LLC and Hi-Tech Associates, LLC
Respectfully submitted,
KAUFMAN DOLOWICH VOLUCK & GONZO
JOSEPH KOURI
JOSEPH J. DE HOPE, JR.
Attorneys for plaintiff Perdana Capital
(Labaun), Inc.
I, Thomas H. Manulkin, of the Law Offices of Michael Q. Eagan, whose ID and password are being used to file this Stipulation and [Proposed] Order, hereby, attest, in accordance with General Order 45 X(B), that Joseph J. De Hope, Jr. of Kaufman Dolowich Voluck and Gonzo, LLP has concurred in this filing.
Respectfully submitted,
LAW OFFICES OF MICHAEL Q. EAGAN
THOMAS H. MANULKIN
Attorneys for defendants Mohammad
Akram Chowdry, Hi-Tech Venture Partners,
LLC and Hi-Tech Associates, LLC
PURSUANT TO STIPULATION, IT IS SO ORDERED
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
THE HON. RICHARD SEEBORG
UNITED STATES DISTRICT JUDGE