Martini e Ricci Iamino S.P.A. - Consortile Societa Agricola v. Trinity Fruit Sales Company, Inc.

Filing 20

Stipulation and request to continue dipositive motion date and trial date; Order, signed by District Judge Anthony W. Ishii on 1/8/2014. (Dispositive Motions filed by 4/15/2014; Pretrial Conference set for 7/9/2014 at 08:30 AM in Courtroom 2 (AWI) before District Judge Anthony W. Ishii; Bench Trial set for 8/19/2014 at 09:00 AM in Courtroom 2 (AWI) before District Judge Anthony W. Ishii) (Figueroa, O)

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JOHN R. CAMPO, ESQ., SBN 157137
DAVID L. STRONG, ESQ., SBN 104939
BRANSON, BRINKOP, GRIFFITH & STRONG, LLP
643 Bair Island Road, Suite 400
Redwood City, California 94063
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]; [e-mail]
Attorneys for Plaintiff MARTINI E RICCI
IAMINO S.P.A. – CONSORTILE SOCIETA AGRICOLA

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MARTINI E RICCI IAMINO S.P.A. –
CONSORTILE SOCIETA AGRICOLA, an
Italian Company,

STIPULATION AND REQUEST TO
CONTINUE DISPOSITIVE MOTION
DATE AND TRIAL DATE;

vs.

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Case No: 1:13-CV-00276-AWI-SAB

Plaintiff,

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643 BAIR ISLAND ROAD, SUITE 400
REDWOOD CITY, CALIFORNIA 94063
TELEPHONE [phone]

BRANSON BRINKOP GRIFFITH & STRONG LLP

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TRINITY FRUIT SALES COMPANY, INC., a
California Corporation, and DOES 1-20,

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Defendants.

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Pursuant to L.R. 144 and Fed. Rules Civ. Proc. 6, the parties to this action request a

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continuance of the dispositive motion due date (currently January 15, 2014) and the pre-trial and

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trial dates for approximately ninety (90) days.

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A.

Good Cause Supporting Continuance

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After certain information was disclosed in discovery, the parties began discussions of an

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out-of-court resolution of this action. The parties are hopeful that with an additional ninety (90)

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days they may reach a settlement of their disputes.

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Given the current deadlines, Plaintiff anticipates filing a dispositive motion on or before

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January 15, 2014. If the dispositive motion does not resolve the matter, the current estimate for

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trial is four (4) days.

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Allowing the parties to continue their settlement discussions will obviate the need for
consumption of court time with respect to a dispositive motion and/or trial.
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[CASE NO. 1:13-CV-00276-AWI-SAB] STIPULATION AND REQUEST TO CONTINUE
DISPOSITIVE MOTION DATE AND TRIAL DATE

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B.

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Prior Extensions
No prior extensions have been requested nor granted.

C.

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Current and Proposed Schedule
The current and proposed schedule is as follows:

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Event

Current Schedule

Proposed Schedule

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Dispositive Motions

January 15, 2014

April 15, 2014

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Pre-Trial Conference

April 9, 2014, 8:30 a.m.

July 9, 2014, 8:30 a.m.

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Trial

May 20, 2014, 9:00 a.m.

August 19, 2014, 9:00 a.m.

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The parties request the Court grant the requested continuance to allow for the opportunity
of settlement.

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IT IS SO STIPULATED.

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643 BAIR ISLAND ROAD, SUITE 400
REDWOOD CITY, CALIFORNIA 94063
TELEPHONE [phone]

BRANSON BRINKOP GRIFFITH & STRONG LLP

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Dated: January 8, 2014

BRANSON, BRINKOP, GRIFFITH & STRONG LLP

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By:

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Dated: January 8, 2014

/s/ John R. Campo
JOHN R. CAMPO
Attorneys for Plaintiff
MARTINI E RICCI IAMINO S.P.A. –
CONSORTILE SOCIETA AGRICOLA

MEUERS LAW FIRM, P.L.

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By:

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/s/ Steven E. Nurenberg (as authorized on January 8, 2014)
LAWRENCE H. MEUERS
STEVEN E. NURENBERG
Attorneys for Defendant
TRINITY FRUIT SALES COMPANY, INC.

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ORDER
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The Proposed Schedule shown above is adopted as the schedule of this action.
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IT IS SO ORDERED.
Dated:

January 8, 2014
SENIOR DISTRICT JUDGE
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[CASE NO. 1:13-CV-00276-AWI-SAB] STIPULATION AND REQUEST TO CONTINUE
DISPOSITIVE MOTION DATE AND TRIAL DATE

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643 BAIR ISLAND ROAD, SUITE 400
REDWOOD CITY, CALIFORNIA 94063
TELEPHONE [phone]

BRANSON BRINKOP GRIFFITH & STRONG LLP

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[CASE NO. 1:13-CV-00276-AWI-SAB] STIPULATION AND REQUEST TO CONTINUE
DISPOSITIVE MOTION DATE AND TRIAL DATE