CALIFORNIA VALLEY LAND COMPANY dba WOOLF ENTERPRISES, and HARRIS WOOLF ALMONDS, Plaintiff,
ROSS SYSTEMS, INC; CDC SOFTWARE, INC.; CDC SOFTWARE CORPORATION; and DOES 1 through 100, inclusive, Defendants.
ROBERT D. EASSA, Bar No. 107970, TARA K. CLANCY, Bar No. 253321, SEDGWICK LLP, San Francisco, California, Attorneys for Defendants ROSS SYSTEMS, INC.; CDC SOFTWARE CORPORATION; and CDC SOFTWARE INC.
WILLOUGHBY, STUART & BENING George W. Dowell, ALEXANDER F. STUART, GEORGE W. DOWELL, Attorneys for Plaintiffs, CALIFORNIA VALLEY LAND, COMPANY dba WOOLF ENTERPRISES, and HARRIS WOOLF ALMONDS.
STIPULATION TO MODIFY SCHEDULING CONFERENCE ORDER; SUPPORTING DECLARATIONS OF GEORGE W. DOWELL AND TARA K. CLANCY; AND ORDER THEREON
SANDRA M. SNYDER, Magistrate Judge.
IT IS HEREBY STIPULATED, by and between, Plaintiffs CALIFORNIA VALLEY LAND COMPANY dba WOOLF ENTERPRISES and HARRIS WOOLF ALMONDS and Defendants ROSS SYSTEMS, INC; CDC SOFTWARE, INC.; and CDC SOFTWARE CORPORATION that the Scheduling Conference Order issued on October 4, 2012 may be modified so that the trial date is continued to February 4, 2014. Furthermore, the parties stipulate that related discovery, motion, and court dates set forth in said Order may be modified as follows:
Original Date Per Modified Date Per New Proposed Date: 2/6/2012 Order: 10/4/12 Or der: Expert Disclosure 10/05/12 02/05/13 07/22/13 Deadline: Supplemental 10/19/12 02/19/13 08/01/13 Expert Disclosure Deadline: Discovery Deadline 10/19/12 02/19/13 08/01/13 (Non-Expert): Discovery Deadline 11/09/12 03/08/13 08/19/13 (Expert): Settlement 11/14/12 01/22/13 at 10:30 a.m. 11/12/13 at 10:00 a.m. Conference: Non-Dispositive 11/16/12 03/15/13 09/03/13 Motion Filing Deadline: Dispositive Motion 12/07/12 04/05/13 9/30/13 Filing Deadline: Pre-Trial 1/25/13 at 8:30 a.m. 05/24/13 at 8:30 a.m. 12/11/13 at 8:30 a.m. Conference: Courtroom 2/AWI Courtroom 2/AWI Courtroom 2/AWI
Trial Date: 3/11/13 at 8:30 a.m. 7/16/13 at 8:30 a.m. 2/4/14 at 8:30 a.m. Courtroom 2/AWI (JT Courtroom 2/AWI (JT Courtroom 2/AWI ~ 3 weeks) ~ 3 weeks) (JT ~ 3 weeks)
This stipulation is made in accordance with Federal Rule of Civil Procedure Rule 16(b)(4), United States District Court Eastern District Local Rule 143, and the provisions of this Court's initial February 6, 2012 Scheduling Conference Order.
IT IS SO STIPULATED THROUGH COUNSEL OF RECORD.
DECLARATION OF TARA K. CLANCY
I, TARA K. CLANCY, declare as follows:
1. I am an attorney at law admitted to practice before the courts of the State of California and the United States District Court for the Eastern District of California. I am an attorney with the law firm of Sedgwick LLP, counsel of record for defendants Ross Systems, Inc.; CDC Software Corporation; and CDC Corporation (collectively "Defendants") in the above-referenced matter. The facts set forth in this declaration are based on my personal knowledge, on matters of which I am informed as counsel, and on my review of the firms' papers and records. If sworn as a witness, I could and would testify competently to these facts.
2. On February 6, 2012, this Court issued an initial Scheduling Conference Order setting a trial date of March 11, 2013. Since then, the parties have been conducting non-expert discovery proceedings including written discovery and document exchanges. In light of the extensive nature of the information requested, the parties granted mutual extensions of time to respond to the discovery requests, with ...