Martin Zurada, VENARDI ZURADA LLP, Attorneys for Plaintiffs, Joe Hand Promotions, Inc.
MARK A. CAMPBELL, (SB# 93595), RONALD R. ROUNDY, (SB#276879), MURPHY, CAMPBELL, ALLISTON & QUINN, Sacramento, CA, Attorneys for Defendants, Art of Cigars, LLC and Eric M. Stanion.
STIPULATION AND ORDER FOR SECOND EXTENSION OF TIME TO RESPOND TO COMPLAINT
TROY L. NUNLEY, District Judge.
NOW COMES the Defendants, ART OF CIGARS LLC and ERIC M. STANION (hereinafter, collectively the "Defendants"), by and through their attorneys of record, MURPHY, CAMPBELL, ALLISTON & QUINN, and Plaintiff JOE HAND PROMOTIONS, INC. (the "Plaintiff") by and through their attorneys of record, Venardi Zurada LLP, (Plaintiffs and Defendants collectively, the "Parties"), who stipulate as follows:
1. WHEREAS, on July 30, 2013, Plaintiff filed a Complaint in the United States District Court for the Eastern District of California, Case No. 2:13-CV-01547-TLN-KJN (the "Action");
2. WHEREAS, Defendants' initial response to Plaintiff's Complaint must have been served and filed on or before September 13, 2013;
3. WHEREAS, the Parties previously agreed to extend the deadline for response to Plaintiff's Complaint by thirty calendar days to October 15, 2013;
4. WHEREAS, the Parties are engaged in discussions to negotiate settlement of the Action without further litigation and without incurring additional costs and court filing fees;
5. WHEREAS, the Parties agree, in good faith, and thus desire to extend Defendants' time to adequately respond to the Complaint and so as to prevent any prejudicial effects for not timely responding to the initial Complaint;
6. WHEREAS, the Parties agree to extend the deadline for responding to the Complaint by up to two weeks after the extended response deadline, in compliance with Local Rule 144 and FRCP Rule 6;
7. WHEREAS, all Parties that have so far appeared in the Action approve this stipulation and proposed order as to form, and certification of service is therefore not necessary pursuant to Local Rule 137 and FRCP Rule 5;
8. WHEREAS, this stipulation will not alter the date of any event or any deadline already fixed by an order of this Court;
9. NOW THEREFORE, it is stipulated by and between Plaintiff and Defendants, through their respective attorneys of record, as follows: Plaintiffs must file a response to ...