The opinion of the court was delivered by: The Honorable Richard Seeborg United States District Court for theNorthern District of California
Thomas M. McInerney State Bar No. 162055 email@example.com 2 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. Steuart Tower, Suite 1300 3 One Market Plaza San Francisco, CA 94105 4 Telephone: 415.442.4810 Facsimile: 415.442.4870 5 Attorneys for Defendant 6 CONVERGYS CORPORATION 7 8
STIPULATION AND [PROPOSED] ORDER FOR A HOLD ON CASE- RELATED DATES AND FOR A INITIAL CASE MANAGEMENT CONFERENCE
STIPULATION AND [PROPOSED] ORDER FOR A HOLD ON CASE-RELATED DATES AND FOR A INITIAL CASE MANAGEMENT CONFERENCE
Conference, which requires the preparation and filing of a Joint Case Management Statement by WHEREAS the parties have other upcoming case-related dates, including for answering the First Amended Complaint, filing of a Second Amended Complaint, and Initial Disclosures; continue these discussions without having to incur further litigation-related expenses related to these upcoming court and case-related dates;
Cordova and defendant Convergys Corporation, by and through their respective counsel, that they hereby jointly request that the Court impose a 30-day hold on this case, during which the parties will not be required to file with the Court or serve on each other any case-related 14 documents which would otherwise be required without this hold. The 30-day hold will run from May 26, 2011 through June 26, 2011. Cordova will have until July 7, 2011 to file (a) his 16 amended fraud claims in a Second Amended Complaint, (b) a stipulation authorizing the filing of 17 an amended complaint alleging additional claims with a Second Amended Complaint, or (c) a 18 motion requesting leave to file a Second Amended Complaint alleging additional claims, if any.
Convergys shall have until two weeks after the filing of an amended complaint to file a 20 responsive pleading, or until July 21, whichever is later. with its calendar on July 21, 2011, or other date available to the Court, assuming the case has not settled and a Request for Dismissal is not submitted to the Court prior to said date. The parties shall submit a Case Management Statement one week prior to the Case Management Conference.
WHEREAS the Court has scheduled a June 9, 2011 Initial Case Management
WHEREAS the parties have had informal settlement disclosures, and would like to THEREFORE, IT IS HEREBY STIPULATED AND AGREED by plaintiff Jon J.
The Court shall schedule an Initial Case Management Conference on a date convenient The parties shall also mutually agree on a date after June 26 for service of Initial Disclosures, assuming the case is not resolved in the interim. 3
Based on the request and stipulation of the parties, and for good cause showing, the Court hereby orders that 30-day day hold on litigation outlined in the parties' stipulation while the 14 15 parties pursue settlement discussions. The Court further orders that a Case Management Conference will be held on July 28 , 2011, at 10 a.m. The parties are to file a joint Case Management Statement one week prior. Cordova shall have until July 7, 2011 18 to file (a) his amended fraud claims in a Second Amended Complaint consistent with the Court's 19
May 9, 2011 order, (b) a stipulation authorizing the filing of an amended complaint alleging 20 additional claims with a Second Amended Complaint, or ...