Free Stipulation - District Court of California - California

Case 3:07-cv-02748-MHP

Document 24

Filed 06/29/2007

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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 BRIEFING AND HEARING RE PRELIMINARY INJUNCTION MOTION [Civil Local Rule 6-2]

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

WHEREAS, in response to Defendants' request to Plaintiff, on June 25, 2007 the parties submitted a Stipulation and Proposed Order ("Stipulation") continuing both the briefing schedule for the parties' opposition and reply briefs, to June 29, 2007 and July 16, 2007 respectively, and the hearing on the Court's Order to Show Cause Why a Preliminary Injunction Should Not Issue, to July 23, 2007; WHEREAS, on June 26, 2007, the Court issued a Clerk's Notice in response to the Stipulation, granting the requested dates, with the exception of calling for Plaintiff's reply brief to be
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STIPULATION AND PROPOSED ORDER CONTINUING HEARING DATE ON PRELIM. INJ. MOTION

C 07-02748 MHP

Case 3:07-cv-02748-MHP

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Filed 06/29/2007

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filed and served on July 9, 2007 in order to ensure that the Court had a sufficient amount of time to review the parties' papers prior to the hearing; WHEREAS, in light of long standing vacation plans of Plaintiff's counsel which will result in him returning to the office on July 9, 2007, the parties have agreed to again continue the hearing date to afford each party sufficient time to fully brief this matter; WHEREAS, the Court has advised the parties that the next two available hearing dates on its calendar are July 30, 2007 and August 27, 2007; WHEREAS, counsel for Defendants is traveling to New Jersey for a deposition on July 30 and prefers the August 27, 2007 hearing date, to which Plaintiff has no objection, and the parties do not believe that continuing the hearing date to August 27 will otherwise affect the schedule in this case; WHEREAS, in light of the available August 27 hearing date, counsel for Defendants have also requested that Defendants be afforded additional time in order to complete their opposition brief and respond to the Complaint; Accordingly, the parties agree as follows: 1. Defendants' opposition brief, currently due to be filed on June 29, 2007, shall be filed

and hand served on or before July 6, 2007, which is also the date by which they will respond to the Complaint; 2. Plaintiffs' reply brief, currently due to be filed on July 9, 2007, shall be filed and hand

served on or before July 30, 2007; 3. The hearing on Plaintiff's Motion for Preliminary Injunction shall be continued from

July 23, 2007, to August 27, 2007; 4. 5. This shall be the final continuance requested by the parties in this matter; and 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.

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STIPULATION AND PROPOSED ORDER CONTINUING HEARING DATE ON PRELIM. INJ. MOTION

C 07-02748 MHP

Case 3:07-cv-02748-MHP

Document 24

Filed 06/29/2007

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