Message: Pacer: EDIG v.Silicon Power - significant progress toward possible settlement
ANTON HANDAL (Bar No. 113812)
anh@handal-law.com
PAMELA C. CHALK (Bar No. 216411)
pchalk@handal-law.com
GABRIEL HEDRICK (Bar No. 220649)
ghedrick@handal-law.com
HANDAL & ASSOCIATES
750 B Street, Suite 2510
San Diego, California 92101
Tel: 619.544.6400
Fax: 619.696.0323
Attorneys for Plaintiff
e.Digital Corporation
ON LU (SBN 242693) (on.lu@novakdruce.com)
NOVAK DRUCE CONNOLLY BOVE + QUIGG LLP
555 Mission Street, Thirty-Fourth Floor
San Francisco, CA 94105
Phone: (415) 814-6161 | Fax: (415) 814-6165
TRIET M. NGUYEN (SBN 245297) (triet.nguyen@novakdruce.com)
NOVAK DRUCE CONNOLLY BOVE + QUIGG LLP
333 So. Grand Avenue, Twenty-Third Floor
Los Angeles, CA 90071
Phone: (213) 787-2500 | Fax: (213) 687-0498
Attorneys for Defendant:
Silicon Power Computer & Communications Inc.; and
Silicon Power Computer & Communications USA, Inc.
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
e.Digital Corporation,
Plaintiff,
v.
Silicon Power Computer &
Communications, Inc.; and
Silicon Power Computer &
Communications USA, Inc.,
Defendants.
Case No. 3:13-cv-2935-H-BGS
JOINT MOTION TO CONTINUE
EARLY NEUTRAL EVALUATION
CONFERENCE CURRENTLY SET
FOR JUNE 27, 2014
ENE Date: June 27, 2014
Time: 10:00 a.m.
Magistrate: Hon. Bernard G. Skomal
Ctrm: 12th Floor (Annex)
DEMAND FOR JURY TRIAL
Assigned to the Honorable
Judge Marilyn L. Huff
Courtroom 15A (Annex)
Case 3:13-cv-02935-H-BGS Document 20 Filed 06/03/14 Page 1 of 4
JOINT MOTION RE: CONTINUING ENE Case No. 3:13-cv-2935-H-BGS
HANDAL & ASSOCIATES
1200 THIRD AVE
SUITE 1321
SAN DIEGO, CA 92101
TEL: 619.544.6400
FAX: 619.696.0323
TO THE CLERK OF THE UNITED STATES DISTRICT COURT FOR
THE SOUTHERN DISTRICT OF CALIFORNIA:
Pursuant to the Court’s Chamber Rules and the Court’s April 16, 2014
“Notice And Order For Telephonic Early Neutral Evaluation Conference In Patent
Cases” (Dkt #17) (hereafter referred to as the “ENE Order”), Plaintiff e.Digital
Corporation (“Plaintiff”) and Defendants Silicon Power Computer &
Communications, Inc.; and, Silicon Power Computer & Communications USA,
Inc. (collectively hereafter referred to as “Defendants” or “Silicon Power”) hereby
present this joint motion seeking to continue the currently scheduled June 27, 2014
Early Neutral Evaluation Conference (“ENE”). Plaintiff and Defendants are
collectively referred to herein as the “Parties.”
No previous requests to continue the ENE have been made in this matter.
II. BASIS FOR REQUEST FOR EXTENSION
The Parties need additional time to meet and confer in this matter with
respect to settlement and the joint discovery plan. It is believed that the Parties may
be close to resolving this matter without assistance of the Court. As such additional
time will allow the Parties to make more significant progress toward possible
settlement. Counsel for the Defendants is also currently traveling out of the country
and so additional time is needed to resume settlement discussions after said
counsel returns. The Parties also need additional time to prepare and file their ENE
briefs in this matter.
As such, the Parties respectfully request to continue the ENE for 30 days or
longer. It is not believed by the Parties that continuing the ENE will impact any
other case management dates.
III. CONCLUSION
Accordingly, the Parties respectfully request that the ENE in this matter be
continued to July 16, 2014 or whatever date is available on the Court’s calendar
thereafter. Pursuant to Local Civil Rule 7.2, Plaintiff will separately submit a
Case 3:13-cv-02935-H-BGS Document 20 Filed 06/03/14 Page 2 of 4
JOINT MOTION RE: CONTINUING ENE Case No. 3:13-cv-2935-H-BGS
-HANDAL & ASSOCIATES
1200 THIRD AVE
SUITE 1321
SAN DIEGO, CA 92101
TEL: 619.544.6400
FAX: 619.696.0323
Proposed Order granting the relief requested.
Dated: June 3, 2014
HANDAL & ASSOCIATES
By: /s/Pamela C. Chalk__________________
Anton N. Handal
Pamela C. Chalk
Gabriel G. Hedrick
Attorneys for Plaintiff
e.Digital Corporation
Dated: June 3, 2014
NOVAK DRUCE CONNOLLY BOVE +
QUIGG LLP
By: /s/On Lu __________________
On Lu
Triet M. Nguyen
Attorneys for Defendants
Silicon Power Computer &
Communications Inc.; and
Silicon Power Computer &
Communications USA, Inc.
anh@handal-law.com
PAMELA C. CHALK (Bar No. 216411)
pchalk@handal-law.com
GABRIEL HEDRICK (Bar No. 220649)
ghedrick@handal-law.com
HANDAL & ASSOCIATES
750 B Street, Suite 2510
San Diego, California 92101
Tel: 619.544.6400
Fax: 619.696.0323
Attorneys for Plaintiff
e.Digital Corporation
ON LU (SBN 242693) (on.lu@novakdruce.com)
NOVAK DRUCE CONNOLLY BOVE + QUIGG LLP
555 Mission Street, Thirty-Fourth Floor
San Francisco, CA 94105
Phone: (415) 814-6161 | Fax: (415) 814-6165
TRIET M. NGUYEN (SBN 245297) (triet.nguyen@novakdruce.com)
NOVAK DRUCE CONNOLLY BOVE + QUIGG LLP
333 So. Grand Avenue, Twenty-Third Floor
Los Angeles, CA 90071
Phone: (213) 787-2500 | Fax: (213) 687-0498
Attorneys for Defendant:
Silicon Power Computer & Communications Inc.; and
Silicon Power Computer & Communications USA, Inc.
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
e.Digital Corporation,
Plaintiff,
v.
Silicon Power Computer &
Communications, Inc.; and
Silicon Power Computer &
Communications USA, Inc.,
Defendants.
Case No. 3:13-cv-2935-H-BGS
JOINT MOTION TO CONTINUE
EARLY NEUTRAL EVALUATION
CONFERENCE CURRENTLY SET
FOR JUNE 27, 2014
ENE Date: June 27, 2014
Time: 10:00 a.m.
Magistrate: Hon. Bernard G. Skomal
Ctrm: 12th Floor (Annex)
DEMAND FOR JURY TRIAL
Assigned to the Honorable
Judge Marilyn L. Huff
Courtroom 15A (Annex)
Case 3:13-cv-02935-H-BGS Document 20 Filed 06/03/14 Page 1 of 4
JOINT MOTION RE: CONTINUING ENE Case No. 3:13-cv-2935-H-BGS
HANDAL & ASSOCIATES
1200 THIRD AVE
SUITE 1321
SAN DIEGO, CA 92101
TEL: 619.544.6400
FAX: 619.696.0323
TO THE CLERK OF THE UNITED STATES DISTRICT COURT FOR
THE SOUTHERN DISTRICT OF CALIFORNIA:
Pursuant to the Court’s Chamber Rules and the Court’s April 16, 2014
“Notice And Order For Telephonic Early Neutral Evaluation Conference In Patent
Cases” (Dkt #17) (hereafter referred to as the “ENE Order”), Plaintiff e.Digital
Corporation (“Plaintiff”) and Defendants Silicon Power Computer &
Communications, Inc.; and, Silicon Power Computer & Communications USA,
Inc. (collectively hereafter referred to as “Defendants” or “Silicon Power”) hereby
present this joint motion seeking to continue the currently scheduled June 27, 2014
Early Neutral Evaluation Conference (“ENE”). Plaintiff and Defendants are
collectively referred to herein as the “Parties.”
No previous requests to continue the ENE have been made in this matter.
II. BASIS FOR REQUEST FOR EXTENSION
The Parties need additional time to meet and confer in this matter with
respect to settlement and the joint discovery plan. It is believed that the Parties may
be close to resolving this matter without assistance of the Court. As such additional
time will allow the Parties to make more significant progress toward possible
settlement. Counsel for the Defendants is also currently traveling out of the country
and so additional time is needed to resume settlement discussions after said
counsel returns. The Parties also need additional time to prepare and file their ENE
briefs in this matter.
As such, the Parties respectfully request to continue the ENE for 30 days or
longer. It is not believed by the Parties that continuing the ENE will impact any
other case management dates.
III. CONCLUSION
Accordingly, the Parties respectfully request that the ENE in this matter be
continued to July 16, 2014 or whatever date is available on the Court’s calendar
thereafter. Pursuant to Local Civil Rule 7.2, Plaintiff will separately submit a
Case 3:13-cv-02935-H-BGS Document 20 Filed 06/03/14 Page 2 of 4
JOINT MOTION RE: CONTINUING ENE Case No. 3:13-cv-2935-H-BGS
-HANDAL & ASSOCIATES
1200 THIRD AVE
SUITE 1321
SAN DIEGO, CA 92101
TEL: 619.544.6400
FAX: 619.696.0323
Proposed Order granting the relief requested.
Dated: June 3, 2014
HANDAL & ASSOCIATES
By: /s/Pamela C. Chalk__________________
Anton N. Handal
Pamela C. Chalk
Gabriel G. Hedrick
Attorneys for Plaintiff
e.Digital Corporation
Dated: June 3, 2014
NOVAK DRUCE CONNOLLY BOVE +
QUIGG LLP
By: /s/On Lu __________________
On Lu
Triet M. Nguyen
Attorneys for Defendants
Silicon Power Computer &
Communications Inc.; and
Silicon Power Computer &
Communications USA, Inc.
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