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Joe Quirk v. Sony Pictures Entertainment Inc.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


March 22, 2013

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

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

STIPULATED REQUEST FOR A SHORT CONTINUANCE OF THE EXPERT DISCOVERY CUTOFF [L.R.17 6-2]

ORDER

Current Expert Cutoff: March 25, 2013 Proposed Expert Cutoff: April 30, 2013 Trial Date: May 7, 2013

Pictures Industries, Inc. ("Columbia"), Pariah, David Koepp and DGK, Inc. (collectively, "defendants"), by and through their undersigned attorneys, hereby file the 5 following stipulated request for an order for a short continuance of the expert discovery 6 cutoff: 7 have been briefed and heard and are currently under submission before this Court: (1) a 10 motion for summary judgment on plaintiff's copyright claims filed on September 27, 11 2012 (ECF No. 69, "Copyright MSJ"), and (2) a motion for summary judgment on 12 plaintiff's implied contract claim filed on December 14, 2012 (ECF No. 93, "Implied 13

Contract MSJ") (together, "dispositive motions"); 14 continuance of the trial date and related dates to facilitate the disposition of these 16 dispositive motions, which may potentially dispose of all claims in this matter prior to 17 expert discovery and final preparation for trial (ECF No. 108, "Stipulated Request for a 18 25 continuance of the expert discovery cutoff to April 30, 2013, which would provide 26 additional time to resolve the pending dispositive motions before the parties and the 27

Court need to expend time and resources relating to expert discovery and final Pursuant to Northern District of California Local Rule 6-2, plaintiff Joe Quirk

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

STIPULATION

A. WHEREAS there are two dispositive motions filed by defendants that

B. WHEREAS, on January 23, 2013, the parties requested a short

Short Continuance of the Trial Date and Related Dates");

C. WHEREAS, on January 23, 2013, the Court issued an order continuing the trial date in this matter to May 7, 2013 to allow the parties and the Court to resolve dispositive motions filed by defendants (ECF No. 109, "Order Continuing Trial Date").

As part of its Order, the Court also continued expert discovery to March 25, 2013;

D. WHEREAS the parties have met and conferred and stipulated to a short preparation for trial. To facilitate this short continuance, the parties agree to reserve the 2 right to supplement pre-trial disclosures with expert discovery as needed; and 3

E. WHEREAS the parties would not be prejudiced by a short continuance 4 of the expert discovery cutoff to April 30, 2013. 5

THEREFORE, the parties stipulate to the aforementioned short continuance of 6 the expert discovery cutoff from March 25, 2013 to April 30, 2013. 7

IT IS SO STIPULATED.

Dated: March 21, 2013 CALDWELL LESLIE & PROCTOR, PC 10 By: /s/ Albert Giang 9 11 Albert Giang 12 Attorneys for Defendants Dated: March 21, 2013 VALLE MAKOFF LLP 13 By: /s/ Rachel S. Bravo 14 Rachel S. Bravo 15 Attorneys for Plaintiff

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Dated: __________________

20130322

© 1992-2013 VersusLaw Inc.



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