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Case 2:12-cv-00850-R-E Document 12

Filed 04/05/12 Page 1 of 4 Page ID #:315

1 STEVEN M. WEINBERG (SBN 235581) smweinberg@holmesweinberg.com 2 SHARONI S. FINKELSTEIN (SBN 271829) 3 sfinkelstein@holmesweinberg.com HOLMES WEINBERG, PC 4 30765 Pacific Coast Highway, Suite 411 5 Malibu, California 90265 Tel: (310) 457-6100 6 Fax: (310) 457-9555 7 Attorneys for Plaintiff 8 Masterfile Corporation 9 10
30765 Pacific Coast Highway, Suite 411 Malibu, California 90265

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UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

HOLMES WEINBERG PC

14 MASTERFILE CORPORATION, 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiff,

Case No. 12-CV-00850 R (Ex)

JOINT STIPULATION TO EXTEND TIME FOR FILING OPPOSITION AND REPLY BRIEFS TO v. DEFENDANTS MOTION FOR CHAGA INTERNATIONAL, a Nevada SUMMARY JUDGMENT AND [PROPOSED] ORDER THEREON corporation; STEVE GOULD, an individual; and MICHAEL TIDD, an individual, Motion Filed: 03/30/2012 Defendants. Current Deadlines/Dates Opposition: 04/16/2012 Reply: 04/23/2012 Hearing: 05/07/2012 Proposed Deadlines/Dates Opposition: 05/16/2012 Reply: 05/23/2012 Hearing: 06/18/2012

-1JOINT STIPULATION TO EXTEND TIME FOR OPPOSITION AND REPLY BRIEFS

Case 2:12-cv-00850-R-E Document 12

Filed 04/05/12 Page 2 of 4 Page ID #:316

WHEREAS on March 30, 2012, Defendants Chaga International (Chaga),

2 Steve Gould (Gould), and Michael Tidd (Tidd) (collectively, Defendants) 3 filed a Notice of Motion and Motion for Summary Judgment in Lieu of Answer 4 (Motion for Summary Judgment) [Dkt. 911]; 5 WHEREAS trial counsel for Masterfile Corporation (Masterfile or

6 Plaintiff) Mr. Weinberg will be out of the country from April 2, 2012 through 7 April 16, 2012, and Ms. Finkelstein will be out of the country from April 7, 2012 8 through April 17, 2012, and both attorneys are in another case currently pending 9 before Chief Judge Ware, wherein discovery is closing April 20, 2012, depositions 10 are being scheduled for April 18, 2012 through April 20, 2012, and certain expert
30765 Pacific Coast Highway, Suite 411 Malibu, California 90265

11 depositions may have to be scheduled for the following week including April 26, 12 2012 because of scheduling conflicts; 13 WHEREAS the parties have agreed to extend the time within which

HOLMES WEINBERG PC

14 Plaintiff may file its opposition to the Motion for Summary Judgment until May 15 16, 2012, to extend the time within which Defendants may file their reply in 16 support of the Motion for Summary Judgment until May 23, 2012, and to continue 17 the hearing on the Motion for Summary Judgment from May 7, 2012 to June 18, 18 2012; 19 20 IT IS HEREBY STIPULATED by and between Masterfile, Chaga, Gould

21 and Tidd, through their respective counsel of record, that Masterfile may file its 22 opposition to the Motion for Summary Judgment on or before May 16, 2012 and 23 Defendants may file their reply in support of the Motion for Summary Judgment 24 on or before May 23, 2012, and the hearing on the Motion for Summary Judgment 25 will take place on June 18, 2012. 26 /// 27 /// 28
-2JOINT STIPULATION TO EXTEND TIME FOR OPPOSITION AND REPLY BRIEFS

Case 2:12-cv-00850-R-E Document 12

Filed 04/05/12 Page 3 of 4 Page ID #:317

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AGREEMENT IT IS NOW THEREFORE AGREED by and between the parties hereto and

3 through their respective counsel that: 4 The deadline for Masterfiles opposition to the Motion for Summary

5 Judgment is May 16, 2012; 6 The deadline for Defendants reply to the Motion for Summary Judgment is

7 May 23, 2012; and 8 The hearing on the Motion for Summary Judgment will be held on June 18,

9 2012 at 10:00 a.m. 10


30765 Pacific Coast Highway, Suite 411 Malibu, California 90265

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

11 Respectfully submitted, 12 13 DATED: April 5, 2012 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28


-3JOINT STIPULATION TO EXTEND TIME FOR OPPOSITION AND REPLY BRIEFS

HOLMES WEINBERG PC

HOLMES WEINBERG, PC By: /s/ Sharoni S. Finkelstein Sharoni S. Finkelstein Attorneys for Plaintiff Masterfile Corporation

DATED: April 5, 2012

BLAKELY LAW GROUP By: /s/ Brent Blakely Brent H. Blakely Attorneys for Defendants Chaga International, Steve Gould, and Michael Tidd

Case 2:12-cv-00850-R-E Document 12

Filed 04/05/12 Page 4 of 4 Page ID #:318

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ATTESTATION I hereby certify that for all conformed signatures indicated by a /s/ I have

3 obtained concurrence in the filing of the document which shall serve in lieu of 4 signature(s) on the document. 5 6 DATED: April 5, 2012 7 8 9 10
30765 Pacific Coast Highway, Suite 411 Malibu, California 90265

By: /s/ Sharoni S. Finkelstein Sharoni S. Finkelstein Attorneys for Plaintiff Masterfile Corporation

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-4JOINT STIPULATION TO EXTEND TIME FOR OPPOSITION AND REPLY BRIEFS

HOLMES WEINBERG PC

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