California Consortium for Agricultural Export, LLC v. Zhonglin Co., LLC

Filing 35

Stipulation and Order for Filing Dispositive Documents, signed by Magistrate Judge Michael J. Seng on 11/13/2014. (Yu, L)

1
2
3
4
5
6

Russell K. Ryan # 139835
MOTSCHIEDLER, MICHAELIDES, WISHON,
BREWER & RYAN, LLP
1690 West Shaw Avenue, Suite 200
Fresno, California 93711
Telephone [phone]
Facsimile [phone]
Attorneys for Plaintiff CALIFORNIA
CONSORTIUM FOR AGRICULTURAL
EXPORT, LLC

7

UNITED STATES DISTRICT COURT

8
EASTERN DISTRICT OF CALIFORNIA

9
10
11
12

CALIFORNIA CONSORTIUM FOR
AGRICULTURAL EXPORT, LLC, a
California Limited Liability Company,
Plaintiff,

13

16

STIPULATION AND ORDER RE
FILING OF DISPOSITIVE
DOCUMENTS

v.

14
15

Case No.: 1:13-cv-00441-LJO-MJS

ZHONGLIN CO., LLC a California
Limited Liability Company and DOES 1
through 20, inclusive,
Defendants.

17
18

Plaintiff California Consortium for Agricultural Export, LLC (“CCAE”)

19
20

and Defendant Zhonglin Co., LLC (“Zhonglin”), by and through their respective

21

counsel of record, hereby STIPULATE AND AGREE as follows:

22

1. The parties filed a Joint Notice of Settlement on September 26, 2014,

23

and the court issued an order requiring dismissal documents to be filed by Wednesday,

24

October 29, 2014. A stipulation and order regarding the filing of the dispositive

25

documents was filed and issued from the court on October 29, 2014 allowing until

26

November 12, 2014.

27

///

28

///

MOTSCHIEDLER,
MICHAELIDES,
WISHON, BREWER &
RYAN, LLP

1
____________________________________________________________________________________________
{00009/0126C//385464.DOC}
Stipulation and Order Re Filing of Dispositive Documents

1

2. Plaintiff has obtained signatures on all settlement documents.

2

Defendant is in the process of obtaining signatures from principals who are located out

3

of the country, specifically in China, and it was necessary for documents to be

4

translated. The parties agree that an extra week of time will be sufficient to obtain fully

5

executed copies of all settlement documents.
3. The new deadline for the filing of dispositive documents shall be

6
7

November 19, 2014.

8

Dated: November 12, 2014

9

MOTSCHIEDLER, MICHAELIDES,
WISHON, BREWER & RYAN, LLP

10
By: /s/Russell K. Ryan
Russell K. Ryan, Attorneys for
Plaintiff California Consortium for
Agricultural Export, LLC

11
12
13
14

Dated: November 12, 2014

SIDLEY AUSTIN LLP

15
16
By: /s/Thomas P. Hanrahan
Thomas P. Hanrahan, Attorneys for
Defendant Zhonglin Co., LLC

17
18
19
20

ORDER

21
22

IT IS SO ORDERED.

23
24
25

Dated:

November 13, 2014

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE

26
27
28
MOTSCHIEDLER,
MICHAELIDES,
WISHON, BREWER &
RYAN, LLP

2
____________________________________________________________________________________________
{00009/0126C//385464.DOC}
Stipulation and Order Re Filing of Dispositive Documents