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Schlumberger Technology Corporation, Inc., A Texas Corporation v. East Charleston

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


August 1, 2011

SCHLUMBERGER TECHNOLOGY CORPORATION, INC., A TEXAS CORPORATION
PLAINTIFF,
v.
EAST CHARLESTON, INC., A CALIFORNIA CORPORATION;
PACIFIC AMERICAN MANAGEMENT COMPANY, A CALIFORNIA LIMITED LIABILITY CORPORATION
DEFENDANTS.

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

J. THOMAS BOER (State Bar No. 199563); jtb@bcltlaw.com RICHARD C. COFFIN (State Bar No. 70562); rcc@bcltlaw.com LAURA S. BERNARD (State Bar No. 197556); lsb@bcltlaw.com BARG COFFIN LEWIS & TRAPP, LLP 350 California Street, 22nd Floor San Francisco, California 94104-1435 Telephone: (415) 228-5400 Fax: (415) 228-5450 Attorneys for Plaintiff SCHLUMBERGER TECHNOLOGY CORPORATION, INC.

STIPULATION AND ORDER CONTINUING CASE MANAGEMENT CONFERENCE; DECLARATION OF J. THOMAS BOER STIPULATION

WHEREAS, plaintiff Schlumberger Technology Corporation, Inc. ("Plaintiff") filed the complaint in this matter on May 27, 2011;

WHEREAS, defendants East Charleston, Inc., and Pacific American Management Company (collectively, "Defendants") waived service of process of the complaint and, consistent 24 with the Federal Rules of Civil Procedures and the applicable Local Rules, Defendants' responses 25 to the complaint are not due until August 15, 2011;

WHEREAS, the Court issued its Order Setting Initial Case Management Conference and ADR Deadlines on May 27, 2011, which set the date of the initial case management conference 28 for August 23, 2011;

case management conference and the parties' obligations under Federal Rules of Civil Procedure

WHEREAS, Plaintiff and Defendants agree that it would be beneficial to postpone the Rule 26 until Defendants have served their responses to the complaint, so that counsel for the 4 parties can have a more meaningful and productive Rule 26 conference.

NOW THEREFORE, consistent with Civil Local Rules 6-2 and 7-12, Plaintiff and Defendants jointly stipulate to, and ask the Court to enter the attached proposed order setting the 7 following case management deadlines: September 13, 2011 Last day to:

� Meet and confer re initial disclosures, early settlement, ADR process selection, and discovery plan � File ADR Certification signed by Parties and Counsel � File either Stipulation to ADR Process or Notice of Need for ADR Phone Conference September 27, 2011 Last day to: � File Rule 26(f) Report � Complete initial disclosures or state objection in Rule 26(f) Report � File Case Management Statement per Standing Order re Contents of Joint Case Management Statement � File consent or declination to proceed before a magistrate judge October 4, 2011 Case Management Conference 2:00 p.m.

IT IS SO STIPULATED.

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.

DECLARATION OF J. THOMAS BOER

I, J. Thomas Boer, declare as follows:

record for plaintiff Schlumberger Technology Corporation, Inc. ("Plaintiff") in this action. I have 5 personal knowledge of each and all of the facts stated in this declaration, except where stated on 6 information and belief. If called to testify as a witness, I could and would do so competently.

2. I have conferred with counsel for defendants East Charleston, Inc. ("ECI"), and

1. I am a partner in the law firm of Barg Coffin Lewis & Trapp LLP, attorneys of Pacific American Management Company ("PAMCO"), and we have agreed that it would be 9 beneficial to postpone the case management conference and the parties' obligations under Federal 10

Rules of Civil Procedure Rule 26 until Defendants have served their responses to the complaint, 11 so that counsel for the parties can have a more meaningful and productive Rule 26 conference.

order.

for the case.

3. There have been no prior time modifications in this case by stipulation or by Court

4. The requested time modification would have no significant impact on the schedule

5. Upon information and belief, a colleague of mine at Barg Coffin Lewis & Trapp LLP, spoke with Judge Grewal's scheduling clerk, who indicated that October 4, 2011 at 2:00 PM was an available time for a rescheduled Case Management Conference.

6. I exchanged electronic-mail correspondence with Jan Greben, counsel for ECI and PAMCO, on July 29 and he authorized me to sign the stipulation on his behalf and file via ECF. foregoing is true and correct. This declaration was executed on July 29, 2011 at San Francisco,

I declare under penalty of perjury under the laws of the State of California that the California.

TOM BOER .

J. Thomas Boer

PROOF OF SERVICE

I am a resident of the State of California, over the age of eighteen years, and not a party to this action. My business address is 350 California Street, 22nd Floor, San Francisco, California 94104.

On July 29, 2011, I served the following listed document(s), by method indicated below on the parties in this action:

by transmitting via facsimile the document(s) listed above to the fax number set forth below on this date before 5:00 p.m. by causing personal delivery overnight delivery by Federal Express of the document(s) listed above to the person at the address set forth below.

by dispatching a messenger from my place of business with instructions to hand-carry the above and make delivery to the following during normal business hours, by leaving a true copy thereof with the person whose name is shown or the person who was apparently in charge of that person's office or residence.

by placing the document(s) listed above in a sealed envelope with postage thereon fully X prepaid, in the United States mail at San Francisco, California addressed as set forth below.

by transmitting via email the document(s) listed above to the email address(es) set forth below on this date before 5 p.m.

Mr. Jan Greben, Esq. Greben & Associates 1332 Anacapa Street, Suite 110 Santa Barbara, CA 93101 20 21

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on July 29, 2011, at San Francisco, California.

JOAN FLAHERTY

JOAN FLAHERTY

20110801

© 1992-2011 VersusLaw Inc.



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