Mitsui O.S.K. Lines Ltd. v. Shine International Transportation (shenzhen) Limited

Northern District of California, cand-4:2015-cv-03343

STIPULATION AND ORDER re {{23}} STIPULATION WITH PROPOSED ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE filed by Mitsui O.S.K. Lines Ltd. Case Management Conference set for 3/29/2016 01:30 PM. Deadline to respond to Amended Complaint is 2/5/16. Signed by Magistrate Judge Kandis A. Westmore on 1/15/16.

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Case 4:15-cv-03343-KAW Document 24 23 Filed 01/15/16 01/14/16 Page 1 of 3 1 CONTE C. CICALA, State Bar No. 173554 conte.cicala@clydeco.us 2 CLYDE & CO US LLP 101 Second Street, 24th Floor 3 San Francisco, California 94105 Telephone: (415) 365-9800 4 Facsimile: (415) 365-9801 5 Attorneys for Plaintiff MITSUI O.S.K. LINES, LTD. 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 SAN FRANCISCO DIVISION 11 MITSUI O.S.K. LINES, LTD., Case No. 4:15-cv-03343-KAW 12 Plaintiff, STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; 13 v. [PROPOSED] ORDER 14 SHINE INTERNATIONAL TRANSPORTATION (SHENZHEN) 15 LIMITED, R.T. EXPRESS INTERNATIONAL, INC., TROY 16 CONTAINER LINE, LTD. and DOES THREE THROUGH TWENTY, 17 Defendants. 18 19 20 WHEREAS, pursuant to stipulation, the default of Defendant Shine International 21 Transportation (Shenzhen) Limited ("Shine") was set aside on November 30, 2015. On 22 December 1, 2015, MOL filed an amended complaint that added two additional defendants. MOL 23 served the amended complaint on Shine on December 1, 2015, and is in the process of serving the 24 two newly-added defendants; and, 25 WHEREAS, since December, MOL and Shine have been engaged in informal document 26 exchanges and settlement discussions and would like to continue this process for as long as it 27 remains productive; and, 28 1971234 Case No. 4:15-cv-03343-KAW STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER Case 4:15-cv-03343-KAW Document 24 23 Filed 01/15/16 01/14/16 Page 2 of 3 1 WHEREAS, consistent with the foregoing, MOL and Shine respectfully believe that 2 certain dates should be extended/continued accordingly. 3 THEREFORE, the parties hereto do stipulated and agree and request the Court to order as 4 follows: 5 1) To extend the date for Shine to respond to the Amended Complaint to and including 6 February 5, 2016 7 2) To continue the CMC scheduled for January 19, 2016 to March 29, 2016; 8 9 Respectfully submitted, 10 Dated: January 14, 2016 CLYDE & CO US LLP 11 By: /s/ Conte C. Cicala San Francisco, California 94105 Conte C. Cicala 101 Second Street, 24 Floor 12 Telephone: (415) 365-9800 CLYDE & CO US LLP Attorneys for Plaintiff th 13 MITSUI O.S.K. LINES, LTD. 14 Dated: January 14, 2016 GONZALEZ DEL VALLE LAW 15 16 By: /s/ Henry P. Gonzalez Henry P. Gonzalez 17 Attorney-in-Fact Shine International Transportation (Shenzhen) 18 Limited 19 20 L.R. 5-l(i) ATTESTATION 21 I, Conte C. Cicala, am the ECF user whose ID and password are being used to file the attached Stipulation to Continue Case Management Conference; [Proposed] Order. 22 In compliance with Local Rule 5-1, I hereby attest that concurrence in the filing of this 23 document has been obtained from the other signatories. 24 Dated: January 14, 2016 /s/ Conte C. Cicala Conte C. Cicala 25 26 27 28 1971234 2 Case No. 3:15-cv-03343 STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER Case 4:15-cv-03343-KAW Document 24 23 Filed 01/15/16 01/14/16 Page 3 of 3 1 [PROPOSED] ORDER 2 Pursuant to stipulation, and good cause having been shown thereby, this Court hereby 3 ORDERS as follows: 4 1) Shine shall have a further extension to respond to the Amended Complaint to and 5 including February 5, 2016 6 2) The Case Management Conference scheduled for January 19, 2016 is continued to March 29, 2016, at 1:30 p.m. 7 8 IT IS SO ORDERED. 9 Dated: 1/15/16 10 11 San Francisco, California 94105 101 Second Street, 24 Floor 12 Telephone: (415) 365-9800 CLYDE & CO US LLP UNITED STATES MAGISTRATE JUDGE th 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1971234 3 Case No. 3:15-cv-03343 STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER