C&G Farms, et al v. Lindsay Foods International, et al

Filing 10

STIPULATION and ORDER to Extend Time to Respond to Complaint, ( Response Due: 5/20/2009.) signed by Magistrate Judge Dennis L. Beck on 4/15/09. (Gil-Garcia, A)

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BUCHALTER NEMER
A PROFES SION AL CORPORAT ION

BUCHALTER NEMER A Professional Corporation DENISE H. FIELD (SBN: 111532) CYNTHIA L. FAIR (SBN: 210816) 333 Market Street, 25th Floor San Francisco, CA 94105-2126 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Attorneys for Defendant TULARE FROZEN FOODS, LLC UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA

C&G FARMS and AMARAL RANCHES, Plaintiffs, vs. LINDSAY FOODS INTERNATIONAL, CAPSTONE BUSINESS CREDIT, LLC, TULARE FROZEN FOODS, LLC and DOES 1-10, Inclusive, Defendants.

Case No. 1:09-CV-00032-LJO-DLB STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT [LOCAL RULE 6-144(a)]

This Stipulation is entered by and between Plaintiffs C&G Farms and Amaral Ranches ("Plaintiffs") and Defendant Tulare Frozen Foods, LLC ("Defendant"), by and through their counsel of record, and is based on the following: WHEREAS, on February 27, 2009, Plaintiffs served Defendant with a copy of the Summons and Complaint; WHEREAS, on March 17 and March 18, the parties stipulated to a 30-day extension of time to respond to the Complaint, pursuant to Local Rule 6-144(a); WHEREAS, the parties have undertaken settlement negotiations, are in the process of exchanging information for the purposes of settlement, and have made significant progress towards settlement;
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SA N FRA N C I S C O

STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT CASE NO.: 1:09-CV-00032-LJO-DLB

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BUCHALTER NEMER
A PROFES SION AL CORPORAT ION

WHEREAS, Defendant's response to the Complaint must be filed on or before April 20, 2009; WHEREAS, in order to permit the parties to resolve this matter without incurring unnecessary fees and costs, the parties seek an additional 30-day extension of time, up to and including May 20, 2009, for Defendant to respond to the Complaint. IT IS THEREFORE STIPULATED that Defendant will have an additional 30-day extension of time, up to and including May 20, 2009, to respond to the Complaint, if necessary. DATED: April 13, 2009 JOHNSON & MONCRIEF A Professional Corporation

By:

PAUL HART Attorneys for Plaintiffs C&G FOODS AND AMARAL RANCHES

/s/ Paul Hart

DATED: April 13, 2009

BUCHALTER NEMER A Professional Corporation

By:

/s/ Cynthia L. Fair CYNTHIA L. FAIR Attorneys for Defendant TULARE FROZEN FOODS, LLC

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SA N FRA N C I S C O

STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT CASE NO: 1:09-CV-00032-LJO-DLB

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BUCHALTER NEMER
A PROFES SION AL CORPORAT ION

ORDER The Court, having read and considered the parties' Stipulation and [Proposed] Order to Extend Time to Respond to Complaint and good cause appearing therefore, hereby orders as follows: IT IS HEREBY ORDERED that Defendant will have an additional 30-day extension of time, up to and including May 20, 2009, to respond to the Complaint, if necessary. ___/s/ Dennis L. Beck______________ HON. DENNIS L. BECK U.S. MAGISTRATE JUDGE

DATED: 15 April 2009

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SA N FRA N C I S C O

STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT CASE NO: 1:09-CV-00032-LJO-DLB