Free Motion for Extension of Time to Amend - District Court of California - California

Case 3:07-cv-02401-W-CAB

Document 20

Filed 05/16/2008

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1 2 3 4 5 6 7 8 9 10 11 12 Plaintiff, 13 v. 14 15 16 17 PAUL KAPLAN and ROBERT WALDER, 18 Counter-Claimants, 19 v. 20 21 22 23 24 25 26 27 28 WHEREAS, the Magistrate Judge's April 23, 2008 Case Management Conference Order established a May 23, 2008 deadline to file any motion to amend the pleadings in the matter; WHEREAS, the parties are in the process of attempting in good faith to negotiate a settlement of the matter; /// 1
Case No. 07-CV-2401 W (CAB) JOINT MOTION TO EXTEND DEADLINE TO AMEND PLEADINGS

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

AMERICAN DIAGNOSTIC MEDICINE, INC.,

CASE NO. 07cv2401 W (CAB) JUDGE: Hon. Thomas J. Whelan CTRM: 7 JOINT MOTION TO EXTEND DEADLINE TO AMEND PLEADINGS

ROBERT WALDER, PAUL KAPLAN, and DOES 1 through 100, inclusive, Defendants.

AMERICAN DIAGNOSTIC MEDICINE, INC. Counter-Defendant.

Case 3:07-cv-02401-W-CAB

Document 20

Filed 05/16/2008

Page 2 of 2

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WHEREAS, at the parties' request, the Magistrate Judge scheduled a Mandatory Settlement Conference on May 21, 2008, at 2:00 p.m. WHEREAS, in light of the possibility that the matter may settle at the May 21, 2008 Mandatory Settlement Conference, the parties wish to avoid any unnecessary expense associated with amending the pleadings and/or filing a motion to amend the pleadings; and WHEREAS, the parties wish to extend their deadline for filing any motion to amend the pleadings by a period of two weeks; THE PARTIES HEREBY JOINTLY MOVE as follows: 1. The May 23, 2008, deadline for the parties to file any motion to amend the

pleadings shall be extended to June 6, 2008. DATED: May 16, 2008 CLAUSEN MILLER P.C.

By: s/Joshua A. Aldort Keith E. Butler Joshua A. Aldort Attorneys for Plaintiff, AMERICAN DIAGNOSTIC MEDICINE, INC. DATED: May 16, 2008 LUCE, FORWARD, HAMILTON & SCRIPPS LLP

By: s/Micah D. Parzen Phillip L. Kossy Micah D. Parzen Attorneys for Defendant/Counter-Claimant, ROBERT WALDER DATED: May 16, 2008 DRINKER BIDDLE & REATH LLP

By: s/Siobhan A. Cullen Siobhan A. Cullen Attorneys for Defendant PAUL KAPLAN

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Case No. 07-CV-2401 W (CAB) JOINT MOTION TO EXTEND DEADLINE TO AMEND PLEADINGS