SECOND STIPULATION FOR ADDITIONAL TIME TO FILE STIPULATION FINALIZING SETTLEMENT
Plaintiffs, CHANEL, INC., a New York corporation ("Chanel") and LOUIS VUITTON MALLETIER, S.A. ("Louis Vuitton"), and the Defendant Tony Bosini ("Bosini"), by and through their undersigned counsel, hereby stipulate to an additional seven days, up to and including March 15, 2010, in which to file the Stipulation finalizing settlement in this matter, and state as follows:
1. On February 4, 2010, the parties submitted their Joint Notice of Settlement advising they anticipated finalizing the settlement in this matter within the next 20 days, i.e. February 24, 2010.
2. On February 24, 2010, the parties submitted a Stipulation for Additional Time to File Stipulation Finalizing Settlement advising the Court that the parties had exchanged settlement papers in this matter, and anticipated submitting the Stipulation finalizing the settlement of this matter to the Court on or before March 8, 2010. On March 1, 2010, this Court entered an Order granting the parties' requested enlargement.
3. Counsel for the Defendant has recently been outside the Court's jurisdiction on another matter. Accordingly, counsel for the Defendant and the Defendant, who resides outside the United States, have been unable to confer regarding the final settlement terms or to obtain the signed settlement documents from the Defendant. Counsel for the Defendant anticipates obtaining final signed documents from the Defendant within the several days, and the parties anticipate being able to file Stipulation with the Court on or before March 15, 2010.
STEPHEN M. GAFFIGAN, P.A., A PROFESSIONAL ASSOCIATION Stephen M. Gaffigan Attorneys for Plaintiffs Chanel, Inc. and Louis Vuitton Malletier, S.A.
LAW OFFICE OF AYAL ABRAMS Ayal Abrams 600 Page Street, #101 San Francisco, California 94117 Telephone: (415) 994-2437 Facsimile: (415) 358-4951 Attorneys for Defendant Tony Bosini
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