Filed: Oct. 10, 2014
Latest Update: Oct. 10, 2014
Summary: STIPULATION AND [PROPOSED] ORDER EXTENDING THE DEADLINE TO FILE MOTION TO COMPEL THOMSON TO RESPOND TO DIRECT ACTION PLAINTIFFS' FIRST SET OF REQUESTS FOR ADMISSION SAMUEL CONTI, District Judge. This Stipulation and Proposed Order Extending the Deadline to File Motion to Compel Thomson to Respond to Direct Action Plaintiffs' First Set of Requests for Admission between certain Direct Action Plaintiffs ("DAPs"), on the one hand, and defendants Thomson S.A. (n/k/a Technicolor SA); Thomson C
Summary: STIPULATION AND [PROPOSED] ORDER EXTENDING THE DEADLINE TO FILE MOTION TO COMPEL THOMSON TO RESPOND TO DIRECT ACTION PLAINTIFFS' FIRST SET OF REQUESTS FOR ADMISSION SAMUEL CONTI, District Judge. This Stipulation and Proposed Order Extending the Deadline to File Motion to Compel Thomson to Respond to Direct Action Plaintiffs' First Set of Requests for Admission between certain Direct Action Plaintiffs ("DAPs"), on the one hand, and defendants Thomson S.A. (n/k/a Technicolor SA); Thomson Co..
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STIPULATION AND [PROPOSED] ORDER EXTENDING THE DEADLINE TO FILE MOTION TO COMPEL THOMSON TO RESPOND TO DIRECT ACTION PLAINTIFFS' FIRST SET OF REQUESTS FOR ADMISSION
SAMUEL CONTI, District Judge.
This Stipulation and Proposed Order Extending the Deadline to File Motion to Compel Thomson to Respond to Direct Action Plaintiffs' First Set of Requests for Admission between certain Direct Action Plaintiffs ("DAPs"), on the one hand, and defendants Thomson S.A. (n/k/a Technicolor SA); Thomson Consumer Electronics, Inc. (n/k/a Technicolor USA, Inc.) (collectively, "Thomson"), on the other hand, is made with respect to the following facts and recitals:
WHEREAS, on March 21, 2014, the Court entered a scheduling order setting the close of fact discovery for September 5, 2014. See Dkt. No. 2459;
WHEREAS, the deadline to file any motion to compel after the discover cut-off is September 12, 2014 (L.R. 37-3);
WHEREAS, on August 1, 2014, the DAPs served their First Set of Requests for Admission on Thomson;
WHEREAS, on September 5, 2014, Thomson served its Responses to DAP's First Set of Requests for Admission and stated objections on various grounds;
WHEREAS, on September 10, 11, 12, and 19, 2014, counsel for the undersigned parties held telephonic meet and confers to discuss deficiencies in Thomson's responses identified by DAPs and have a bona fide intent to continue doing so;
WHEREAS, on September 12, 2014, the undersigned parties filed a stipulation extending DAPs' deadline to file a motion to compel relating to DAPs' First Set of Requests of Admission until September 22, 2014, see Dkt. No. 2840;
WHEREAS, the undersigned parties desire to continue to meet and confer regarding Thomson's responses to DAPs' First Set of Requests for Admission;
WHEREAS, the DAPs and Thomson have conferred by and through their counsel and, subject to the Court's approval, HEREBY STIPULATE AS FOLLOWS:
1. Subject to the parties' meet and confer discussion, the Plaintiffs provided Thomson with a revised list of documents.
2. Subject to the parties' meet and confer discussion, Thomson will review the revised list for inclusion on, and will consider executing, a declaration or stipulation related to their authenticity and business record status by September 26, 2014.
3. The undersigned parties agree to extend the deadline for the Plaintiffs to file a motion to compel relating to the Plaintiffs First Set of Requests for Admission, to the extent one is deemed necessary by Plaintiffs, to October 3, 2014.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
