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Joe Quirk, Inc., et al v. Sony Pictures Entertainment

November 28, 2012

JOE QUIRK, INC., ET AL., PLAINTIFF,
v.
SONY PICTURES ENTERTAINMENT
DEFENDANTS.



The opinion of the court was delivered by: Honorable Richard Seeborg District Court Judge

STIPULATION AND [PROPOSED] ORDER TO PERMIT PLAINTIFF TO FILE A FIFTH AMENDED COMPLAINT TO ADD DEFENDANT KOEPP'S "LOAN-OUT COMPANY" AS A DEFENDANT [L.R. 6-1(b)] Trial Date: March 25, 2013 Fourth Amended Complaint Filed: 8/2/12

("plaintiff") and defendants Sony Pictures Entertainment Inc. ("Sony"), Columbia Pictures 3

"defendants") (plaintiff and defendants together, "stipulating parties"), by and through their 5 undersigned attorneys, hereby stipulate as follows: 6 7

A. WHEREAS, plaintiff intends to file a Fifth Amended Complaint to add

9 defendant, DGK, Inc., defendant Koepp's "loan-out company," to all claims for relief in the 10 above-entitled action based upon information obtained in discovery; 11

12 claims against any defendants, including the loan-out company, defendants have agreed to 13 permit plaintiff to file his Fifth Amended Complaint and to add DGK, Inc. as a defendant to 14 all claims for relief alleged in the Complaint, on the terms and conditions described below; 15

1. Plaintiff may file his Fifth Amended Complaint to add defendant DGK, Inc.

17 as a defendant to all claims for relief alleged in the Complaint; 18 19 other than the newly added party making disclosures under Federal Rule of Civil Procedure 20

Complaint; 22

23 motion for summary judgment filed by defendants, or any future motion for summary 24 judgment that may be filed (any order on the pending or any future motion for summary 25 judgment relating to defendant Koepp shall also apply to DGK, Inc.); and 26

Amended Complaint on behalf of defendant DGK, Inc. by electronic mail; and 28 29 30

33

Pursuant to Northern District of California Local Rule 6-1(b), ...


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