Free Stipulation - District Court of California - California

Case 3:07-cv-04015-MMC

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Filed 11/14/2007

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Christopher W. Brown, SBN 243472
The DuBoff Law Group, LLC
6665 SW Hampton Street, Suite 200
Portland, Oregon 97223-8357
Telephone: (503) 968-8111
Facsimile: (503) 968-7228
[email protected]
Attorney for Defendants Michael D. Sage and Susan Gilmour Sage Lawrence G. Townsend, Esq., SBN 88184
[email protected]
Linda Joy Kattwinkel, Esq. SBN 164283
[email protected]
Owen, Wickersham & Erickson, PC
455 Market Street, Ste. 1910
San Francisco, CA 94105
phone: (415) 882-3200
fax: (415) 882-3232
Attorneys for Plaintiff Leaf Lines, LLC

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UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA
LEAF LINES, LLC, a California Company, Case No. CV074015MMC STIPULATION AND [PROPOSED] ORDER TO CONTINIJE CASE MANAGEMENT CONFERENCE, ALLOW DEFENDANTS' APPEARANCE BY TELEPHONE, AND EXTEND TIME TO RESPOND TO COMPLAINT

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Plaintiff, 17

v.

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MICHAEL D. SAGE and SUSAN GILMOUR
SAGE, Washington State residents dba SAGE
DESIGNS, and DOES 1-100


Counsel report that they have met and conferred regarding this request and have reached the following stipulation pursuant to Civil L.R. 6-2 and 7-12:
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The Parties request the Court to continue the Case Management Conference

("CMC") scheduled for November 30,2007, for two weeks to December 14, 2007, or such later

-1- STIPULATED AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE AND ALLOW DEFENDANTS' APPEARANCE BY TELEPHONE Case No. CV074015MMC
\\Jelad\Clients\3400-3499\3443\Pleadings\Stipulated MOTION TO CONTINUE CMC.DOC

Case 3:07-cv-04015-MMC

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Filed 11/14/2007

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date as is available to the Court and that all related deadlines in the Court's Order Setting Initial Case Management Conference and ADR Deadlines be adjusted accordingly. 2. The Parties stipulate to a request that the Court allow Defendants' counsel to

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participate in the Case Management Conference by telephone.

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3.

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

Complaint be extended to December 6,2007. Good cause is demonstrated by the facts established in the Declaration of Christopher W. Brown ("Brown Decl.") filed herewith. Dated: / (/; 1{

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W. Brown, SBN 243472 Attorney for Defendants Michael Sage and Susan Gilmour Sage, dba Sage Designs

~~ iStOPh;
[PROPOSED] ORDER

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Dated: November 14,2007

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

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Pursuant to the Stipulation above, the Initial Case Management Conference set for November 30, 2007 is continued to December 14, 2007, 10:30 a.m. in Courtroom 7. All related deadlines in the court's Order Setting Initial Case Management Conference and ADR Deadlines are adjusted accordingly. Defendants' counsel may appear at the Case Management Conference by telephone. The time for Defendants to respond to the Complaint is extended to December 6, 2007. IT IS SO ORDERED. DATED this - - day of November, 2007.

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HONORABLE MAXINE M. CHESNEY UNITED STATES DISTRICT JUDGE
-2- STIPULATED AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE AND ALLOW DEFENDANTS ' APPEARANCE BY TELEPHONE Case No. CV074015MMC
IIJeladlClienlsl 3400-34991 3443l PleadingslSlipulal ed MOTION TO CONTINUE CMC.DOC

Case 3:07-cv-04015-MMC

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Filed 11/14/2007

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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 CONTINUE CASE MANAGEMENT CONFERENCE, ALLOW DEFENDANTS' APPEARANCE BY TELEPHONE, AND EXTEND TIME TO RESPOND TO COlVIPLAINTon the individuals listed below: 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: [email protected] Attorney for Plaintiff, Leaf Lines, LLC

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[ X ] by mailing a full, true, and correct copy thereof in a sealed first-class postage-prepaid 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 . [] by causing a full, true, and correct copy thereof to be hand-delivered to the attorne y at the attorney's last-known office address listed above on the date set forth below. [] by sending a full, true, and correct copy thereof via overnight courier in a sealed , prepaid envelope, addressed to the attorne y as shown above, the last-known office address of the attorn ey, on the date set forth below. [] by faxing a full, true, and correct cop y thereof to the attorne y at the fax number shown above, which is the last-known fax number for the attorney's office, on the date set forth below. The recei ving fax machine was operating at the time of service and the transmission was properly completed. DATED this 14th day of November, 2007 .

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1 - CERTIFICATE OF SERVICE
IIJeladl Clientsl3400-34991 3443l Pleadingsl CERTIFICATE OF SERVICE STIP . TO CONT INUE CMC.D OC