Free Stipulation - District Court of California - California

Case 3:07-cv-02748-MHP

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Filed 06/25/2007

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HARVEY SISKIND LLP IAN K. BOYD (State Bar No. 191434) [email protected] SETH I. APPEL (State Bar No. 233421) [email protected] Four Embarcadero Center, 39th Floor San Francisco, California 94111 Telephone: (415) 354-0100 Facsimile: (415) 391-7124 Attorneys for Plaintiff Mark Lillge d/b/a Creative Marketing Concepts

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION MARK LILLGE d/b/a CREATIVE MARKETING CONCEPTS, Case No. C 07-02748 MHP STIPULATION AND [PROPOSED] ORDER TO CONTINUE PRELIMINARY INJUNCTION HEARING [Civil Local Rule 6-2]

Plaintiff, vs. ANDREW VERITY and CHRISTINA CHANG, Defendants.

On June 8, 2007, the parties submitted a stipulation and proposed order extending the time until June 25, 2007 for Defendants Andrew Verity and Christina Chang ("Defendants") to file their Opposition to the Court's Order to Show Cause Why a Preliminary Injunction Should Not Issue; WHEREAS, the Court has not yet ruled on the parties' stipulation; WHEREAS, Defendants have requested additional time to prepare and file the Opposition, in part to ensure that they complete the taking of a deposition before filing their Opposition;

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Case 3:07-cv-02748-MHP

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WHEREAS, Plaintiff does not object to Defendants' request, provided that Defendants accommodate certain pre-existing vacation plans, just as Plaintiff accommodated Defendants in originally scheduling the briefing on the preliminary injunction hearing; Accordingly, the parties agree as follows: 1. Defendants' Opposition, originally due to be filed on June 11, 2007, shall be filed and

hand served on or before June 29, 2007; 2. Plaintiffs' Reply brief, originally due to be filed on June 18, 2007, shall be filed and

hand served on or before July 16, 2007; 3. The hearing on Plaintiff's Motion for Preliminary Injunction shall be continued from

July 9, 2007, to July 23, 2007; and 4. Pursuant to F.R.C.P. 65(b), the Court's Temporary Restraining Order shall remain in

effect until such time as the Court rules on Plaintiff's motion for a preliminary injunction. DATED: June 25, 2007 HARVEY SISKIND LLP IAN K. BOYD SETH I. APPEL

By

/s/ Ian K. Boyd Attorneys for Plaintiff Mark Lillge d/b/a/ Creative Marketing Concepts

DATED: June 25, 2007

CHANDLER, WOOD, HARRINGTON & MAFFLY RICHARD HARRINGTON By /s/ Richard Harrington Attorneys for Defendants Andrew Verity and Christina Chang

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Dated: ________, 2007 Honorable Marilyn Hall Patel United States District Court
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