UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
February 11, 2013
BRADFORD TECHNOLOGIES, INC., PLAINTIFF,
NCV SOFTWARE.COM, ET AL., AS MODIFIED
The opinion of the court was delivered by: Elizabeth D. Laporte United States Magistrate
STIPULATION AND ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE FOR 60 DAYS
WHEREAS, the Court entered a Stipulated Order Regarding Defendants Karma Technologies, LLC's And John David Biggers' Motion For An Order To Show Cause Why Plaintiff, Jeffrey Bradford And Roger Wintle Should Not Be Held In Contempt of Court And For Further Relief And Sanctions on December 6, 2012 (the "Sanctions Order"); WHEREAS, pursuant to the Sanctions Order, Defendants are conducting expedited 6 7 discovery concerning their three source code discs and the extent to which they were accessed, reviewed, copied, downloaded and/or saved by Bradford Technologies, Inc., Jeffrey Bradford 9 and/or AppraisalWorld, Inc., in violation of the Stipulated Protective Order in this matter; 10 WHEREAS, in anticipation of the completion of the foregoing expedited discovery 11 within two (2) months, the Court scheduled a case management conference for February 19, 12 2013, at 10:00 a.m.;
WHEREAS, Defendants have not yet been able to complete the expedited discovery 14 15 contemplated by the Sanctions Order due, in part, to the fact that Defendants' retained, independent expert was not given access to Mr. Bradford's personal laptop until January 21, 17 2013, to obtain a forensic image for analysis: 18
WHEREAS, Defendants' independent experts need additional time to complete their 19 analyses, and Defendants need additional time to schedule and conduct relevant depositions once 20 the experts finish their analyses; 21 WHEREAS, to permit Defendants sufficient time to conduct and complete their 22 23 expedited discovery, the parties wish to continue the case management conference scheduled for 24 February 19, 2013, by approximately sixty (60) days; 25 IT IS HEREBY STIPULATED and AGREED by and between the foregoing parties in 26 this matter, through their respective counsel of record, as follows: 27 28 23 at 3:00 p.m.
1. The case management conference should be continued until April 22, 2013, to 2 permit Defendants to complete the expedited discovery contemplated by the Sanctions Order, 3 and for their experts to complete their analyses. 4 2. Any party may request an order from the Court to expedite the case management 5 conference, or to otherwise seek expedited relief from Court, for good cause. 6 7
IT IS SO STIPULATED.
Dated: February 11, 2013 ANDERSON & KARRENBERG, P.C. 9 By: /s/ Heather M. Sneddon - and - GREENBERG TRAURIG, LLP Kurt A. Kappes Greg Sperla Attorneys for Defendants KARMA TECHNOLOGIES, LLC JOHN DAVID BIGGERS 16 17 Dated: February 11, 2013 T H E H E R I T A G E L A W G R O U P18 19 By: /s/ Jill Schachter Attorneys for Plaintiff BRADFORD TECHNOLOGIES, INC.
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