Sorensen v. Lexar Media, Inc., No. 5:2008cv00095 - Document 183 (N.D. Cal. 2011)
Court Description: STIPULATION AND ORDER Granting 182 Joint MOTION to Continue CMC by one week (stipulated) filed by Jens Erik Sorensen. ***10/28/2011 Deadlines terminated. Joint Case Management Statement due by 10/28/2011. Case Management Conference set for 11/4/2011 10:00 AM in Courtroom 1, 5th Floor, San Jose. The parties are further ordered to provide a proposed order for all further requests of thisnature. Signed by Judge Edward J. Davila on 10/19/2011. (ecg, COURT STAFF) (Filed on 10/19/2011)
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Sorensen v. Lexar Media, Inc. 10 11 12 13 14 15 24 27 28 R NIA SAN JOSE DIVISION JENS ERIK SORENSEN, as Trustee of SORENSEN RESEARCH AND DEVELOPMENT TRUST, Plaintiff v. LEXAR MEDIA, INC., a Delaware corporation; and DOES 1 – 100, 25 26 C FOR THE NORTHERN DISTRICT OF CALIFORNIA 22 23 F D IS T IC T O R UNITED STATES DISTRICT COURT 18 21 N Attorneys for Defendant LEXAR MEDIA, INC. 17 20 Davila KEVIN KUDLAC (pro hac vice) WEIL, GOTSHAL & MANGES LLP 700 Louisiana, Suite 1600 Houston, TX 77008 Telephone: (512) 546-5000 16 19 ER w a rd J . H 9 JARED BOBROW, SBN 133712 WEIL, GOTSHAL & MANGES LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065 Telephone: (650) 802-3000 d J u d ge E RT 8 NO 7 ED ORDER T IS SO DIFIED I AS MO FO 6 Attorney for Plaintiff JENS ERIK SORENSEN, as Trustee of SORENSEN RESEARCH AND DEVELOPMENT TRUST LI 5 RT U O 4 S DISTRICT TE C TA A 3 S 2 MELODY A. KRAMER, SBN 169984 KRAMER LAW OFFICE, INC. 9930 Mesa Rim Road, Suite 1600 San Diego, California 92121 Telephone (858) 362-3150 UNIT ED 1 Doc. 183 Defendants. _________________________________ and related counterclaims. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 08cv00095 EJD STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE BY ONE WEEK & ORDER THEREON November 4, 2011 Date: TBD 10:00 a.m. Time: TBD Courtroom 1, 5th Floor Judge: The Hon. Edward J. Davila Dockets.Justia.com 1 Plaintiff Jens Erik Sorensen, as Trustee of Sorensen Research and 2 Development Trust (“Plaintiff”) is requesting a one-week continuance of the Case 3 Management Conference scheduled for October 28, 2011 at 10:00 a.m. (see Doc. 4 #179) for the following reasons: 5 6 7 1. Plaintiff’s counsel, Ms. Kramer, will be out-of-state for a preplanned and unchangeable commitment from October 28-31, 2011; 2. Counsel who will shortly be entering her appearance as additional 8 counsel for Plaintiff, Patricia Shackelford, and was scheduled to appear on October 9 28th, has not yet had her admission to the Northern District processed and therefore 10 11 12 cannot yet enter her appearance in the case. Defendant Lexar Media, Inc. (“Defendant”) is amenable to this scheduling change and hereby stipulates to the requested continuance. 13 14 RESPECTFULLY SUBMITTED this Tuesday, October 18, 2011, 15 16 I, Melody Kramer, attest that concurrence in the filing of the document has 17 been obtained from each of the signatories below, which shall serve in lieu of their 18 signatures on the document. 19 20 21 JENS ERIK SORENSEN, as Trustee of SORENSEN RESEARCH AND DEVELOPMENT TRUST, Plaintiff 25 /s/ Melody A. Kramer MELODY A. KRAMER, SBN 169984 9930 Mesa Rim Road, Suite 1600 San Diego, California 92121 Telephone (858) 362-3150 26 LEXAR MEDIA, INC., Defendant 22 23 24 27 28 _/s/ Jared Bobrow_______________ JARED BOBROW, SBN 133712 ii. Case No. 08CV0095 EJD 1 2 3 4 5 6 7 WEIL, GOTSHAL & MANGES LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065 Telephone: (650) 802-3000 KEVIN KUDLAC (pro hac vice) WEIL, GOTSHAL & MANGES LLP 700 Louisiana, Suite 1600 Houston, TX 77008 Telephone: (512) 546-5000 8 9 10 11 12 13 14 15 ORDER Good cause appearing therefore, the parties stipulation is GRANTED. The Case Management Conference currently scheduled for October 28, 2011, is VACATED and rescheduled for November 4, 2011, at 10:00 a.m. The parties shall file a Joint Case Management Statement on or before October 28, 2011. The parties are further ordered to provide a proposed order for all further requests of this nature. IT IS SO ORDERED. EDWARD J. DAVILA United States District Judge 16 17 18 19 20 21 22 23 24 25 26 27 28 iii. Case No. 08CV0095 EJD DECLARATION OF MELODY A. KRAMER 1 2 3 I, MELODY A. KRAMER, declare: 4 1. I am not a party to the present action. I am over the age of eighteen. I 5 have personal knowledge of the facts contained within the following paragraphs, and 6 could and would competently testify thereto if called as a witness in a court of law. 7 2. At all times relevant herein I have been an attorney for Sorensen 8 Research and Development Trust (“Sorensen”), Plaintiff in the above-captioned 9 matter. 10 11 3. This declaration is made in support of the parties Stipulation to Continue Case Management Conference by One Week. 12 4. 13 above, namely, 14 a. 15 The requested continuance is made for the reasons set forth in the Motion I will be out-of-state for a preplanned and unchangeable commitment from October 28-31, 2011; b. 16 Counsel who will shortly be entering her appearance as additional 17 counsel for Plaintiff, Patricia Shackelford, and was scheduled to appear on October 18 28th, has not yet had her admission to the Northern District processed and therefore 19 cannot yet enter her appearance in the case. 20 5. I contacted Mr. Bobrow, counsel for Defendant Lexar Media, Inc. 21 (“Defendant”), and he indicated Defendant’s willingness to agree to this scheduling 22 change and join in a stipulation for the same. 23 6. Within the last year there has only been one request to modify time in this 24 case was Plaintiff’s Motion to Shorten Time for Hearing on its Motion for Immediate Lift 25 of Stay which was granted by the Court at Doc. #173. 26 modification was in April 2010 wherein Plaintiff requested an expedited hearing date for a 27 Motion to Reopen Case, which request was denied at Doc. #151. The last prior request for time 28 iv. Case No. 08CV0095 EJD 7. 1 The effect of the requested time modification to this case will be minimal in 2 that the requested continuance is only by one week. Furthermore, the time modification 3 will allow me, as lead counsel in this case, to be present for the Case Management 4 Conference instead of another attorney who does not have as much familiarity with the 5 case. 6 SWORN TO UNDER PENALTY OF PERJURY on Tuesday, October 18, 2011 in San 7 Diego, California. 8 9 10 /s/ Melody A. Kramer Melody A. Kramer, Esq. Attorney for Plaintiff 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 v. Case No. 08CV0095 EJD 1 PROOF OF SERVICE 2 I, Melody A. Kramer, declare: I am and was at the time of this service working within in 3 the County of San Diego, California. I am over the age of 18 year and not a party to the within 4 action. My business address is the Kramer Law Office, Inc., 9930 Mesa Rim Road, Suite 1600, 5 San Diego, California, 92121. 6 7 8 On Tuesday, October 18, 2011 I served the following documents: STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE BY ONE WEEK 9 10 11 12 13 14 15 16 17 18 PERSON(S) SERVED PARTY(IES) SERVED METHOD OF SERVICE Jared Bobrow Weil, Gotshal & Manges LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065 jared.bobrow@weil.com Lexar Media, Inc. Email--Pleadings Filed with the Court via CM/ECF Kevin Kudlac Weil, Gotshal & Manges LLP Kevin.kudlac@weil.com 700 Louisiana, Suite 1600 Houston, Texas 77002 Lexar Media, Inc. Email--Pleadings Filed with the Court via CM/ECF 19 20 21 22 23 24 25 26 27 (Personal Service) I caused to be personally served in a sealed envelope hand-delivered to the office of counsel during regular business hours. (Federal Express) I deposited or caused to be deposited today with Federal Express in a sealed envelope containing a true copy of the foregoing documents with fees fully prepaid addressed to the above noted addressee for overnight delivery. (Facsimile) I caused a true copy of the foregoing documents to be transmitted by facsimile machine to the above noted addressees. The facsimile transmissions were reported as complete and without error. (Email) I emailed a true copy of the foregoing documents to an email address represented to be the correct email address for the above noted addressee. 28 1. Case No. 08CV0095 EJD 1 2 3 4 X (Email--Pleadings Filed with the Court) Pursuant to Local Rules, I electronically filed this document via the CM/ECF system for the United States District Court for the Southern District of California. (U.S. Mail) I mailed a true copy of the foregoing documents to a mail address represented to be the correct mail address for the above noted addressee. 5 I declare that the foregoing is true and correct, and that this declaration was executed on Tuesday, 6 October 18, 2011, in San Diego, California. 7 8 /s/ Melody A. Kramer 9 Melody A. Kramer 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2. Case No. 08CV0095 EJD
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