Free Stipulation - District Court of California - California

Case 3:07-cv-04015-MMC

Document 23

Filed 01/03/2008

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Chrstopher W. Brown, SBN 243472
1 The DuBoff Law Group, LLC

6665 SW Hampton Street, Suite 200
2 Portland, Oregon 97223-8357

Telephone: (503) 968-8111
3 Facsimile: (503) 968-7228

cbrown~duboffaw.com
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Attorney for Defendants Michael D. Sage
5 and Susan Gilmour Sage
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Lawrence G. Townsend, Esq., SBN 88184 7 1townsend~owe.com Linda Joy Kattwinkel, Esq. SBN 164283

8 lik~owe.com
Owen, Wickersham & Erickson, PC
9 455 Market Street, Ste. 1910

San Francisco, CA 94105
10 phone: (415) 882-3200
fax: (415) 882-3232
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Attorneys for Plaintiff Leaf Lines, LLC
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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

LEAF LINES, LLC, a California Company,
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Case No. CV074015MMC
STIPULATION AND (PROPOSED)

Plaintiff,
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v.
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ORDER TO EXTEND TIME TO RESPOND TO FIRST AMENDED COMPLAINT

MICHAEL D. SAGE and SUSAN GILMOUR
19 SAGE, Washington State residents dba SAGE

DESIGNS, and DOES 1-100
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Defendants.

22 Counsel report that they have met and conferred regarding this request and have reached
23 the following stipulation pursuant to Civil L.R. 6-2 and 7-12:
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1.

The Parties stipulate to a request that the time for Defendants' response to the

25 Complaint be extended to January 22,2008.

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1- STIPULATION AN (PROPOSEDJ ORDER TO EXTEND TIME TO RESPOND TO FIRST AMENDED COMPLAINT Case No. CV074015MMC
\\Jelad\Clients\3400-3499\3443\Pleadings\Stipulated MOTION TO EXTEND ANS FOR 1ST AM COMPL.DOC

Case 3:07-cv-04015-MMC

Document 23

Filed 01/03/2008

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2.

As noted in the Case Management Report, the paries resumed negotiations for
purchase of the Leaf Lines business by Sage Designs, or alternate resolution, in
September 2007. The parties have been attempting to settle this matter and are

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committed to continuing such efforts. The additional time wil permit the paries
to preserve their resources for this purpose.

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Good cause is demonstrated by the facts established herein.
Dated: January 3, 2008

Dated: January 3, 2008
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Isl Christopher Brown Christopher W. Brown, SBN 243472 Attorney for Defendants Michael Sage and Susan Gilmour Sage, dba Sage Designs

Isl Linda Joy Kattwinkel Linda Joy Kattwinkel, SBN 164283 Attorney for Plaintiff Leaf Lines, LLC

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13 (PROPOSEDJ ORDER
14 Pursuant to the Stipulation above, the time for Defendants to respond to the First
15 Amended Complaint is extended to January 22,2008.

16 IT is SO ORDERED.
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DATED this

day of Januar, 2008.

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HONORABLE MAXINE M. CHESNEY UNITED STATES DISTRICT JUDGE

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2- STIPULATION AND (PROPOSEDJ ORDER TO EXTEND TIME TO RESPOND TO FIRST AMENDED COMPLAINT Case No. CV074015MMC
\\Jelad\Clients\3400-3499\3443\Pleadings\Stipulated MOTION TO EXTEND ANS FOR 1ST AM COMPL.DOC

Case 3:07-cv-04015-MMC

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CERTIFICATE OF SERVICE
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I hereby certify that on the date set forth below, I served a true copy of the foregoing

STIPULATION AND (PROPOSED) ORDER TO EXTEND TIME TO RESPOND TO
FIRST AMENDED COMPLAINT on the individuals listed below:
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Linda Joy Kattwinkel Owen, Wickersham & Erickson, P.C. 455 Market Street, Suite 1910 San Francisco, CA 94105 Tel: 415-882-3200 Fax: 415-882-3232 Email: ljkêowe.com

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Attorney for Plaintiff, Leaf Lines, LLC

(J by mailng a full, true, and correct copy thereof in a sealed first-class postage-prepaid
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envelope, addressed to the attorney as shown above, the last-known office address of

the attorney, and deposited with the United States Postal Service at Portland, Oregon, on the date set forth below.

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(J by causing a full, true, and correct copy thereof to be hand-delivered to the attorney at
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the attorney's last-known office address listed above on the date set forth below.
(J by sending a full, true, and correct copy thereof via overnight courier in a sealed,

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prepaid envelope, addressed to the attorney as shown above, the last-known office the attorney, on the date set forth below. address of
(J by faxing a full, true, and correct copy thereof to the attorney at the fax number shown

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above, which is the last-known fax number for the attorney's offce, on the date set forth below. The receiving fax machine was operating at the time of service and the transmission was properly completed.

( x J by emailng a full, true and correct copy thereof to the attorney at the email address
shown above, which is the last-known email address for the attorney, on the date set forth below.
DATED this 3rd day of January, 2008.

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~'" ler,~L "l~ e ifer M Paralegal
1- CERTIFICATE OF SERVICE
\\Jelad\clients\3400-3499\3443\Pleadings\cERTIFICATE OF SERVICE STIP. AND PROPOSED DOC ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT.

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