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American Heavy Moving and Rigging, Inc. v. Sheedy Drayage Co.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION


September 30, 2009

AMERICAN HEAVY MOVING AND RIGGING, INC., A CALIFORNIA CORPORATION, PLAINTIFF,
v.
SHEEDY DRAYAGE CO., A CALIFORNIA CORPORATION, DEFENDANT.

The opinion of the court was delivered by: Honorable Ronald M. Whyte United States District Judge

STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND ORDER Initial Case Mgmt. Conf: October 2, 2009

Plaintiff American Heavy Moving & Rigging, Inc. ("AHM") and defendant Sheedy Drayage Co. ("Sheedy"), by and through their undersigned respective counsel, hereby agree and stipulate to continue the Initial Case Management Conference currently scheduled for October 2, 2009 at 10:30 a.m. and respectfully request an Order from the Court scheduling the continued date not less than 30 days following disposition of Sheedy's currently pending Motion to Dismiss and Motion to Stay the Action (the "Motions"), which were heard by the Court on September 11, 2009.

The pending Motions are potentially dispositive of the case. This is a patent case and subject to the Court's patent local rules, which require extensive disclosures on an accelerated schedule.

Absent the requested continuance, the parties will have to expend significant resources to comply with the meet and confer and disclosure efforts that might be made moot by the ruling on the Motions. Because of the reassignment of this matter to the Honorable Ronald M. Whyte, the motions were heard unusually close to the time for the Initial Case Management Conference.

The parties hereby request that the Court issue an Order, for good cause shown, in accordance with the foregoing stipulation.

DATED: September 22, 2009.

PURSUANT TO STIPULATION, IT IS SO ORDERED:

**The Court hereby continues the Case Management Conference to December 4, 2009 at 10:30 a.m. The parties are required to file a Joint Case Management Statement by November 25, 2009.

20090930

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