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Reflex Packaging, Inc v. Stephen Gould Corporation

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION


January 30, 2011

REFLEX PACKAGING, INC.,
PLAINTIFF,
v.
STEPHEN GOULD CORPORATION,
DEFENDANT.
STEPHEN GOULD CORPORATION, COUNTERCLAIMANT,
v.
REFLEX PACKAGING, INC.,
COUNTER-DEFENDANT.

The opinion of the court was delivered by: Hon. Paul Singh Grewal United States Magistrate Judge

STIPULATION REQUESTING ORDER SHORTENING TIME TO RESOLVE DISPUTE REGARDING CONTENTS OF PROTECTIVE ORDER

(Local Rule 6-2)

[Complaint Filed: July 1, 2010]

hearing on a motion to resolve their dispute regarding the content of a protective order regarding 3 discovery to be entered in this matter. The Parties request that the matter be heard as part of the

On January 12, 2011, Judge Koh entered a Minute Order and Case Management Order. In

that Order, the Court instructed the parties to submit a stipulated protective order by January 26, 7

The Parties to this action request that the Court enter an order shortening the time for a

Court's normal civil law and motion calendar at 10:00 a.m. on February 8, 2011.

2011. The parties have negotiated in good faith, and have been able to resolve most, although 8 not all, issues regarding the protective order. On January 26, the Parties notified Judge Koh 9

(a) that they had not reached an agreement on all items of the protective order, and (b) that the 10 parties would submit their remaining disputes to Magistrate Judge Grewal, who has been assigned 11 to handle discovery regarding the case.

13 expedited resolution of their dispute, because Judge Koh has referred the case to an early 14 settlement conference before Magistrate Judge Chen. That settlement conference is set to take 15 place on March 1, 2011. Settlement Conference Statements are to be lodged with Judge Chen no 16 later than February 15. The protective order is necessary to facilitate the exchange of information 17 in advance of the settlement conference and the submission of Settlement Conference Statements.

The parties believe that the remaining issues are discrete and that extensive briefing is unnecessary 19 to adequately present their positions to the Court for resolution. 20

schedule:

Content of Protective Order

As set forth in the accompanying declaration of Michael M. Carlson, the parties seek

As a result, the Parties joint request that the Court enter an order adopting the following

January 28, 2011 Plaintiff's Brief in Support of Motion to Resolve Issues Regarding

February 1, 2011 Defendant's Opposition Brief

No reply brief will be filed.

February 8, 2011 Hearing on Motion

Respectfully submitted,

Dated: January 28, 2011 SCHNADER HARRISON SEGAL & LEWIS LLP By: /s/ Michael M. Carlson Michael M. Carlson Attorneys for Plaintiff Reflex Packaging, Inc. Dated: January 28, 2011 DRINKER BIDDLE & REATH LLP By: /s/ Gregory J. Lavorgna Gregory J. Lavorgna Attorneys for Defendant Stephen Gould Corporation

PURSUANT TO STIPULATION, IT IS SO ORDERED.

20110130

© 1992-2011 VersusLaw Inc.



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