Free Stipulation - District Court of California - California

Case 5:08-cv-01841-RMW

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Filed 08/28/2008

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KRISTEN GARCIA DUMONT, State Bar No. 191554 ERIN M. DOYLE, State Bar No. 233113 WILSON SONSINI GOODRICH & ROSATI Professional Corporation One Market Street Spear Tower, Suite 3300 San Francisco, CA 94105-1126 Telephone: (415) 947-2000 Facsimile: (415) 947-2099 Email: [email protected] Email: [email protected] Attorneys for Defendant M2 MEDICAL, INC. ISRAEL G. RAMIREZ, State Bar No. 176366 RAMIREZ & ASSOCIATES 653 N. San Pedro Street, #C San Jose, CA 95110 Telephone: (408) 947-7244 Email: [email protected] Attorneys for Plaintiff Philippe Z. Zatta UNITED STATES DISTRICT COURT

15 NORTHERN DISTRICT OF CALIFORNIA 16 17 PHILIPPE Z. ZATTA, 18 Plaintiff, 19 v. 20 M2 MEDICAL, INC., 21 Defendant. 22 23 24 25 26 27 28
JOINT STIPULATON AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE CASE NO.: C08-01841 RMW

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CASE NO.: C08-01841 RMW JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE

Case 5:08-cv-01841-RMW

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Filed 08/28/2008

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Plaintiff Philippe Zatta ("Plaintiff") and Defendant M2 Medical, Inc. ("Defendant") (jointly, the "Parties"), by and through their undersigned counsel, hereby enter into the following stipulation: WHEREAS, pursuant to the Court's June 10, 2008 Notice of Setting Case Management Conference ("CMC Notice") and Rule 26 of the Federal Rules of Civil Procedure, there is a Case Management Conference scheduled for September 19, 2008 at 10:30 a.m., and the Parties' Joint Case Management Statement is due by September 12, 2008; WHEREAS, Israel Ramirez, Esq. recently substituted in as counsel for Plaintiff, who was initially proceeding pro se; WHEREAS, on August 15, 2008, the Parties stipulated that Plaintiff will file an amended complaint by August 29, 2008; WHEREAS, to allow sufficient time for Plaintiff's new counsel familiarize himself with the case, and to allow the Parties sufficient time to file their initial pleadings in this matter prior to conducting a Rule 26(f) Conference, filing a Joint Case Management Statement, and completing Initial Disclosures, the Parties desire to continue the case management deadlines and hearing set forth in the Court's CMC Notice for approximately 30 days;

JOINT STIPULATON AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE CASE NO.: C08-01841 RMW

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Case 5:08-cv-01841-RMW

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Filed 08/28/2008

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NOW, THEREFORE, the Parties hereby stipulate that the Case Management Conference currently set for September 19, 2008 shall be continued until October 24, 2008 or sometime thereafter, on a date convenient for the Court. NOW, THEREFORE, the Parties hereby further stipulate that the related deadlines for conducting a Rule 26(f) Conference, filing a Joint Case Management Statement, and completing Initial Disclosures shall also be continued pursuant to the new Case Management Conference date and applicable Federal Rules of Civil Procedure.

IT IS SO STIPULATED. Dated: August 28, 2008 WILSON SONSINI GOODRICH & ROSATI Professional Corporation By: _____________/S/__________________ Erin M. Doyle [email protected] Attorneys for Defendant M2 MEDICAL, INC. Dated: August 28, 2008 RAMIREZ & ASSOCIATES By: _____________/S/__________________ Israel Gaxiola Ramirez [email protected] Attorneys for Plaintiff PHILIPPE Z. ZATTA IT IS SO ORDERED.

_________________________________ The Honorable Ronald M. Whyte United States District Judge

JOINT STIPULATON AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE CASE NO.: C08-01841 RMW

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