Case 3:07-cv-04820-MMC
Document 58
Filed 03/13/2008
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Kevin C. McCann (SB# 120874) PAUL, HASTINGS, JANOFSKY & WALKER LLP 55 Second Street Twenty-Fourth Floor San Francisco, CA 94105 Telephone: (415) 856-7000 Facsimile: (415) 856-7100 Email: [email protected] [Additional Defendant's counsel identified below] Attorneys for Defendant AEROMECHANICAL SERVICES LTD. JEFFREY K. LEE, CA Bar No. 212465 KIMBERLY A. DONOVAN, CA Bar No. 160729 GCA LAW PARTNERS LLP 1891 Landings Drive Mountain View, CA 94043 Phone No.: (650) 428-3900 Fax No.: (650) 428-3901 Email: [email protected] Email: [email protected] [Additional Plaintiff's counsel identified below] Attorneys for Plaintiff STAR NAVIGATION SYSTEMS GROUP LTD. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
STAR NAVIGATION SYSTEMS GROUP LTD., Plaintiff, v. AEROMECHANICAL SERVICES LTD., Defendant.
CASE NO. C 07-4820 (MMC) STIPULATED REQUEST TO CONTINUE: (1) HEARING ON AMS'S MOTION TO DISMISS; AND (2) INITIAL CASE MANAGEMENT CONFERENCE, AND [PROPOSED] ORDER Date: March 21, 2008 Time: 9:00 a.m. Place: Courtroom 7, 19th Floor Honorable: Maxine M. Chesney
Case No. C 07-4820 (MMC)
STIPULATED REQUEST TO CONTINUE: (1) HEARING ON AMS'S MOTION TO DISMISS; & (2) INITIAL CMC
Case 3:07-cv-04820-MMC
Document 58
Filed 03/13/2008
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Pursuant to Civil Local Rules 16-2(d), 6-2 and 7-12, Defendant Aeromechanical Services Ltd. ("AMS") and Plaintiff Star Navigation Systems Group Ltd. ("Star") hereby stipulate and jointly request that this Court continue the: (1) hearing on AMS's Motion to Dismiss to April 11, 2008; and (2) the Initial Case Management Conference to Friday, May 23, 2008. The parties jointly declare the following in support of this request: WHEREAS, the Court's October 24, 2007 Case Management Conference Order (D.I. 12) set the Initial Case Management Conference for February 22, 2008; WHEREAS, this Court referred AMS's Motion to Dismiss (D.I. 29) to Judge William F. Nielsen of the United States District Court for the Eastern District of Washington (D.I. 50) on January 15, 2008; WHEREAS, Judge Nielsen was scheduled to hear argument on February 27, 2008; WHEREAS, this Court continued (by the parties' request) the Initial Case Management Conference to April 25, 2008 because of the referral to Judge Nielsen (D.I. 54); WHEREAS, this Court withdrew the referral to Judge Nielsen on February 7, 2008, and set a hearing on AMS's Motion to Dismiss for March 21, 2008 (D.I. 57); WHEREAS, counsel for AMS have a conflicting trial date in Ohio on March 21, 2008; WHEREAS, the parties have conferred and determined that a hearing date of April 11, 2008 for AMS's Motion to Dismiss is open for both parties, and that movement of the hearing to this date would have no effect on the schedule for this case; WHEREAS, the parties have conferred and determined that moving the Initial Case Management Conference (and associated deadlines) to May 23, 2008 would be appropriate to allow the Court time to decide AMS's Motion to Dismiss, and that this change is in the agreed best interests of the parties and would have no effect on the schedule for this case; WHEREAS, it would best serve judicial economy for this Court to have a reasonable time to decide AMS's Motion to Dismiss before conducting the Initial Case Management Conference; WHEREAS, the parties have sought a previous modification to the Case Management Conference Order only once - in view of the referral of to Judge Nielsen (D.I. 53);
-1Case No. C 07-4820 (MMC)
STIPULATED REQUEST TO CONTINUE: (1) HEARING ON AMS'S MOTION TO DISMISS; & (2) INITIAL CMC
Case 3:07-cv-04820-MMC
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WHEREFORE Plaintiff Star and Defendant AMS hereby jointly request that the Court continue the: (1) hearing on AMS's Motion to Dismiss to April 11, 2008; and (2) the Initial Case Management Conference to Friday, May 23, 2008 (with all associated deadlines continued accordingly). Dated: March __, 2007 Kevin C. McCann (SB# 120874) PAUL, HASTINGS, JANOFSKY & WALKER LLP 55 Second Street Twenty-Fourth Floor San Francisco, CA 94105 Telephone: (415) 856-7000 Facsimile: (415) 856-7100 Email: [email protected] Robert M. Masters (admitted pro hac vice) Timothy P. Cremen (admitted pro hac vice) Bhaskar Kakarla (admitted pro hac vice) PAUL, HASTINGS, JANOFSKY & WALKER LLP 875 15th St., N.W. Washington, DC 20005 Telephone: (202) 551-1700 Facsimile: (202) 551-1705 Email: [email protected] Email: [email protected] Email: [email protected] Attorneys for Defendant AEROMECHANICAL SERVICES LTD. By:________ /s/ Kevin C. McCann_________ Kevin C. McCann
Attorneys for Defendant AEROMECHANICAL SERVICES LTD. Dated: March __, 2007 DANIEL P. ALBERS (admitted pro hac vice) JEFFREY A. RUPPEL (admitted pro hac vice) BARNES & THORNBURG LLP One N. Wacker Drive, Suite 4400 Chicago, IL 60606 Phone No.: (312) 357-1313 Fax No.: (312) 759-5646 Email: [email protected] Email: [email protected] CHRISTINE H. MCCARTHY (admitted pro hac vice) BARNES & THORNBURG LLP 750 17th Street N.W., Suite 900 Washington, D.C. 20006-4675 Phone No.: (202) 289-1313 Fax No.: (202) 289-1330 Email: [email protected] -2Case No. C 07-4820 (MMC) STIPULATED REQUEST TO CONTINUE: (1) HEARING ON AMS'S MOTION TO DISMISS; & (2) INITIAL CMC
Case 3:07-cv-04820-MMC
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JEFFREY K. LEE, CA Bar No. 212465 KIMBERLY A. DONOVAN, CA Bar No. 160729 GCA LAW PARTNERS LLP 1891 Landings Drive Mountain View, CA 94043 Phone No.: (650) 428-3900 Fax No.: (650) 428-3901 Email: [email protected] Email: [email protected] Attorneys for Plaintiff STAR NAVIGATION SYSTEMS GROUP LTD. By:_____________________________________ Jeffrey A. Ruppel Attorneys for Plaintiff STAR NAVIGATION SYSTEMS GROUP LTD.
-3Case No. C 07-4820 (MMC)
STIPULATED REQUEST TO CONTINUE: (1) HEARING ON AMS'S MOTION TO DISMISS; & (2) INITIAL CMC
Case 3:07-cv-04820-MMC
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Dated: ______________, 2008
ORDER After consideration of the parties' Stipulated Request To Continue: (1) Hearing On AMS's Motion To Dismiss; and (2) Initial Case Management Conference, and for good cause appearing: PURSUANT TO STIPULATION, IT IS SO ORDERED that: (1) the hearing on Defendant Aeromechanical Services, Ltd.'s Motion to Dismiss is continued to April 11, 2008 at _________ in Courtroom No. 7, 19th Floor, Federal Building; (2) the Initial Case Management Conference is hereby continued to Friday, May 23, 2008 at _________ in Courtroom No. 7, 19th Floor, Federal Building. All deadlines associated with the Initial Case Management Conference shall be continued accordingly.
____________________________________ MAXINE M. CHESNEY United States District Judge
-4Case No. C 07-4820 (MMC)
STIPULATED REQUEST TO CONTINUE: (1) HEARING ON AMS'S MOTION TO DISMISS; & (2) INITIAL CMC