Filed: Feb. 13, 2015
Latest Update: Feb. 13, 2015
Summary: JOINT STIPULATION TO CONTINUE ALL DEADLINES PENDING COMPLETION OF SETTLEMENT AGREEMENT SUSAN Y. ILLSTON, District Judge. Pursuant to Civil L.R. 6-2 and 7-1(a)(2), Plaintiff Sunbeam Products, Inc. d/b/a Jarden Consumer Solutions ("Sunbeam") and Defendant Oliso, Inc. ("Oliso") hereby jointly request that the Court extend all pending deadlines for 45 days to allow the parties to complete a settlement agreement reflecting settlement terms upon which the parties have reached agreement. In support o
Summary: JOINT STIPULATION TO CONTINUE ALL DEADLINES PENDING COMPLETION OF SETTLEMENT AGREEMENT SUSAN Y. ILLSTON, District Judge. Pursuant to Civil L.R. 6-2 and 7-1(a)(2), Plaintiff Sunbeam Products, Inc. d/b/a Jarden Consumer Solutions ("Sunbeam") and Defendant Oliso, Inc. ("Oliso") hereby jointly request that the Court extend all pending deadlines for 45 days to allow the parties to complete a settlement agreement reflecting settlement terms upon which the parties have reached agreement. In support of..
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JOINT STIPULATION TO CONTINUE ALL DEADLINES PENDING COMPLETION OF SETTLEMENT AGREEMENT
SUSAN Y. ILLSTON, District Judge.
Pursuant to Civil L.R. 6-2 and 7-1(a)(2), Plaintiff Sunbeam Products, Inc. d/b/a Jarden Consumer Solutions ("Sunbeam") and Defendant Oliso, Inc. ("Oliso") hereby jointly request that the Court extend all pending deadlines for 45 days to allow the parties to complete a settlement agreement reflecting settlement terms upon which the parties have reached agreement. In support of this request, the parties state the following:
1. The parties participated in mediation on October 29, 2014. (Dkt. No. 65.) Although the parties did not settle the case at the mediation, they continued to discuss settlement.
2. The parties have reached agreement on settlement terms and have begun drafting a settlement agreement, and they anticipate filing a notice of voluntary dismissal on or before March 20, 2015.
3. Accordingly, the parties jointly request that the Court extend the pending deadlines as follows to provide them sufficient time to finalize a settlement agreement and meet the terms thereof:
Presently
Who Event Scheduled Date Proposed Date
to complete Claim
Parties Construction Discovery February 16, 2015 April 2, 2015
(L.R. 4.3)
to file Opening Claim
Plaintiff Construction Briefs (L.R. March 2, 2015 April 16, 2015
4-5a)
to file Responsive Claim
Defendant Construction Briefs (L.R. March 16, 2015 April 30, 2015
4-5b)
to file Reply Claim
Plaintiff Construction Briefs (L.R. March 23, 2015 May 7, 2015
4-5c)
to conduct Technology
Parties N/A N/A
Tutorial (if needed)
to conduct and participate
Court, in Claim Construction April 22, 2015 TBD (pursuant to
Parties Hearing Court's schedule)
to complete Fact
Parties TBD TBD
Discovery
Parties to serve Expert Reports TBD TBD
to serve Expert Rebuttal
Parties Reports TBD TBD
to complete Expert
Parties Discovery TBD TBD
Parties to file Dispositive Motions TBD TBD
to conduct hearing on
Court Dispositive Motions TBD TBD
to conduct and participate
Court, in Final Pretrial TBD TBD
Parties Conference
Court, To conduct and participate
Parties in Jury Trial TBD TBD
4. This limited continuance is for good cause. The parties are not submitting this request for the purposes of delay but, rather, so that they may have sufficient time to finalize a settlement agreement and complete the terms of the agreement, and dismiss this matter forthwith in its entirety.
