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Jarrad L. Wood (SBN 3 1 0688))
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jlwood@reedsmith.com COUNTY OF
REED SMITH LLP SAN aeguua%’f~5§'f's"r%?c'§°
355 South Grand Avenue, Suite 2900
Los Angeles, CA 90071—1514 NOV 03 2021
Telephonez+1 213 457 8000
Facsimile: +1 213 457 8080 r
BY ,
CUAUHE’EMOC EPUTY
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Attorneysfor Defendant, SDC Nutrition Inc. ,
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
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Delawale
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FENCHEM, INC., No.1 CIV SB 21 14881
of
State
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N STIPULATION TO CONTINUE TRIAL
LLP
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Plaintiff, DATE AND ALL CASE DEADLINES I
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formed
SMITH
vs. [Filed Concurrently with Proposed Order]
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partnership
REED
SDC NUTRITION, INC.; and DOES 1 through Honorable Wilfred J. Schneider, Dept. 32
t—I U1
liability
25, inclusive, .
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STIPULATION TO CONTINUE TRIAL DATE AND ALL CASE DEADLINES
TO THE HONORABLE COURT AND TO ALL PARTIES AND THEIR RESPECTIVE
ATTORNEYS OF RECORD HEREIN:
Plaintiff Fenchem, Inc. (“Plaintiff”), on one hand, and Defendant SDC Nutrition, Inc.
(“Defendant,” and together with Plaintiff, the “Parties”), on the other hand, by and through their
\OOOQONUI#WNr—‘
respective counsel of record, stipulate as follows:
WHEREAS, Plaintiff filed the Complaint in the Superior Court of California on or about
May 20, 2020;
WHEREAS, on May 31, 2022, the Court set the trial date in this matter as May 22, 2023 with
a Trial Readiness Conference date 0f May 18, 2023;
WHEREAS, based on the trial date, the last day to file and serve a motion for summary
Delaware
judgment or summary adjudication is currently set for January 31, 2023;
of
State
WHEREAS, on August 2, 2022, Defendant served its first set 0f written discovery 0n
the
LLP
in
Plaintiff;
formed
SMITH
partnership
WHEREAS, on September 20, 2022, Plaintiff served responses and objections to
REED
Defendant’s first set of discovery;
liability
limited
WHEREAS, on October 6, 2022, Defendant sent Plaintiff a meet and confer letter identifying
A
discovery disputes with regard t0 Plaintiff’s discovery responses (the “Discovery Disputes”);
NNNNNNNNNt—lr—Ir—d’d—ap—Hp—Ih—r—I
WHEREAS, as of the date of this Stipulation, the Parties have not resolved the Discovery
OOQQUl-RUJNHOOOONONUIAWNi—‘O
Disputes;
WHEREAS, the Parties have met and conferred and believe that additional time Will assist
the Parties in resolving the Discovery Disputes and may avoid the need to litigate a motion to
compel with respect t0 the Discovery Disputes;
WHEREAS, Plaintiff has not sought discovery in the above-captioned matter and intends to
seek discovery shortly;
WHEREAS, the Parties have met and conferred and agree that the Court’s interest in
resolving cases on their merits following discovery will be furthered by continuing the trial date and
all case deadlines by three (3) months;
///
_ 1 _
STIPULATION TO CONTINUE TRIAL SETTING CONFERENCE
Preview
V ngjmm ‘ u r-«:;,z\1\ -, n g5; (x v; x. 54' " P fr Um 3"“; ‘Y i 1‘14 v Jarrad L. Wood (SBN 3 1 0688)) SUFFERIIGREBOQRT jlwood@reedsmith.com COUNTY OF REED SMITH LLP SAN aeguua%’f~5§'f's"r%?c'§° 355 South Grand Avenue, Suite 2900 Los Angeles, CA 90071—1514 NOV 03 2021 Telephonez+1 213 457 8000 Facsimile: +1 213 457 8080 r BY , CUAUHE’EMOC EPUTY \OOOQQUI-PUJNp—n Attorneysfor Defendant, SDC Nutrition Inc. , 0&5qu SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO H O Delawale y—t H FENCHEM, INC., No.1 CIV SB 21 14881 of State —n N STIPULATION TO CONTINUE TRIAL LLP the in Plaintiff, DATE AND ALL CASE DEADLINES I H DJ formed SMITH vs. [Filed Concurrently with Proposed Order] p—t g partnership REED SDC NUTRITION, INC.; and DOES 1 through Honorable Wilfred J. Schneider, Dept. 32 t—I U1 liability 25, inclusive, . V fi‘&() ‘ r—I O\ Defendants. i limited )0); 1w I37 I h ' A b—t \l r—l 0° —I o NO N *—‘ NN N U) Nh N U1 Na N \l NW STIPULATION TO CONTINUE TRIAL DATE AND ALL CASE DEADLINES TO THE HONORABLE COURT AND TO ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD HEREIN: Plaintiff Fenchem, Inc. (“Plaintiff”), on one hand, and Defendant SDC Nutrition, Inc. (“Defendant,” and together with Plaintiff, the “Parties”), on the other hand, by and through their \OOOQONUI#WNr—‘ respective counsel of record, stipulate as follows: WHEREAS, Plaintiff filed the Complaint in the Superior Court of California on or about May 20, 2020; WHEREAS, on May 31, 2022, the Court set the trial date in this matter as May 22, 2023 with a Trial Readiness Conference date 0f May 18, 2023; WHEREAS, based on the trial date, the last day to file and serve a motion for summary Delaware judgment or summary adjudication is currently set for January 31, 2023; of State WHEREAS, on August 2, 2022, Defendant served its first set 0f written discovery 0n the LLP in Plaintiff; formed SMITH partnership WHEREAS, on September 20, 2022, Plaintiff served responses and objections to REED Defendant’s first set of discovery; liability limited WHEREAS, on October 6, 2022, Defendant sent Plaintiff a meet and confer letter identifying A discovery disputes with regard t0 Plaintiff’s discovery responses (the “Discovery Disputes”); NNNNNNNNNt—lr—Ir—d’d—ap—Hp—Ih—r—I WHEREAS, as of the date of this Stipulation, the Parties have not resolved the Discovery OOQQUl-RUJNHOOOONONUIAWNi—‘O Disputes; WHEREAS, the Parties have met and conferred and believe that additional time Will assist the Parties in resolving the Discovery Disputes and may avoid the need to litigate a motion to compel with respect t0 the Discovery Disputes; WHEREAS, Plaintiff has not sought discovery in the above-captioned matter and intends to seek discovery shortly; WHEREAS, the Parties have met and conferred and agree that the Court’s interest in resolving cases on their merits following discovery will be furthered by continuing the trial date and all case deadlines by three (3) months; /// _ 1 _ STIPULATION TO CONTINUE TRIAL SETTING CONFERENCE