September 24, 2013
United States Small Business Administration in its capacity as Receiver for Rocket Ventures II SBIC, L.P., Plaintiff,
Rocket Ventures II, L.P., a California limited partnership; Rocket Ventures II CEO Fund, L.P., a California limited partnership; Rocket Ventures SBIC Partners, LLC, a Delaware limited liability company; Cordusio Societa Fiduciaria Per Azioni Lozia Federico; Kenneth W.& Melissa Baldwin; Paul Cantwell; Peter Ayrton Cheese; Yves Derville; Richard S. Cuccioli; Alistair Anderson Donald; Philippe Gire; Jean-Claude Guez; Joseph Hawes & Chrisopher Eyden; Alan John Healey; Craig Foster Heimark; David E. Kropp; Gregory Charles Meekings; Michele Liberato; Fred Cucchi; ValorLife; Alberto Gandini; Rijete Pty. Ltd.; Christopher Stainton; Tyna Development; Thomas Tynan; Patrice Vinet; Hahei Limited; Michel Saunier; Michel Roujansky; Nigel Backwith; Justine Lumb; Andrew Middleton; Ajmair Singh Bhullar; Estate of Grant A. Dove; Luca Casiraghi; David Mather, Defendants.
T. Scott Tate, Gregory C. Nuti, Melissa S. Lor, SCHNADER HARRISON SEGAL & LEWIS LLP, San Francisco, CA.
Arlene M. Embrey, Trial Attorney, Office of General Counsel U.S. Small Business Administration, Washington, D.C., Attorneys for Plaintiff United States Small Business Administration in its capacity as Receiver for Rocket Ventures II SBIC, L.P.
Cooley LLP, Gordon C. Atkinson, Abby Pringle, Counsel for Rocket Ventures SBIC Partners, LLC; Rocket Ventures II CEO Fund, L.P.; and Rocket Ventures II, L.P.
STIPULATION TO CONTINUE PRETRIAL CONFERENCE AND TRIAL DATES
JEFFREY S. WHITE, District Judge.
Plaintiff United States Small Business Administration in its capacity as Receiver for Rocket Ventures II, L.P. ("Plaintiff") and the entity defendants, Rocket Ventures II L.P., Rocket Ventures II CEO Fund, L.P., and Rocket Ventures SBIC Partners, LLC (collectively, the "Entity Defendants" and together with the Plaintiff, the "Parties"), by and through their respective counsel of record, hereby stipulate and agree as follows:
1. On September 10, 2013, this Court entered an "Order (1) Adopting Report and Recommendation on Plaintiff's Motions for Default Judgment, (2) Requiring Status Report, and (3) Continuing Dates [Doc. No. 161], ordering, among other things, that the pretrial conference and trial in this action are continued to November 12, 2013 and December 9, 2013, respectively.
2. As the Parties have been in active communication to resolve the matter without further litigation, the Parties agree that a pretrial conference and trial before the end of this year would not be judicious. Recently, the Plaintiff requested to review certain documents from the Entity Defendants, who have been working cooperatively with the Plaintiff. The Entity Defendants are currently gathering such documents and will be producing them to the Plaintiff shortly.
3. Additionally, due to unexpected circumstances regarding the medical condition of lead counsel for the Entity Defendants, the parties believe it would be most prudent to defer the pretrial conference and trial dates for at least six (6) months from the current dates set to allow time to transition to new counsel for the Entity Defendants, should this case not be resolved before that time. The declaration from Ann M. Mooney, colleague to lead counsel for the Entity Defendants, is concurrently filed herewith.
THEREFORE, UPON APPROVAL BY THE COURT, it is hereby stipulated by and between the Parties as follows:
(1) that the pretrial conference set for November 12, 2013 shall be continued to May 12, 2013, at 1:30 p.m.; and
(2) that the bench trial set for December 9, 2013 shall be continued to June 9, 2013, at 8:00 a.m.
PURSUANT TO STIPULATION, IT IS SO ORDERED: AS MODIFIED ABOVE, IT IS SO ORDERED.