Pacific Press Publishing Association, Inc. v Consolidated Graphics, Inc., et al

Filing 16

STIPULATION and ORDER signed by Judge Frank C. Damrell, Jr. on 4/29/2010 ORDERING 15 that CGX's and American Lithographers' new deadline to answer or otherwise respond to the Complaint shall be 5/31/2010, and that the parties' deadline to file the Rule 26 (f) Joint Status Report shall be 6/15/2010. (Reader, L)

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KIRK M. NUZUM (SBN 144745 ) Email: [e-mail] CYRIL J. DANTCHEV (SBN 129585) Email: [e-mail] BUCHANAN INGERSOLL & ROONEY LLP 600 West Broadway, Suite 1100 San Diego, CA 92101 Telephone: [phone] Facsimile: [phone] S. LLOYD SMITH Email: [e-mail] BUCHANAN INGERSOLL & ROONEY P.C. 17137 King Street, Suite 500 Alexandria, VA 22314 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff, PACIFIC PRESS PUBLISHING ASSOCIATION, INC. UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION Case No. 2:10-CV-00109-FCD-KJM STIPULATION AND ORDER EXTENDING TIME TO FILE RESPONSIVE PLEADINGS AND TO FILE RULE 26 (F) JOINT STATUS REPORT Judge: Dept: Hon. Frank C. Damrell, Jr. Courtroom 2, 15th Floor

13 PACIFIC PRESS PUBLISHING ASSOCIATION, INC., 14 Plaintiff, 15 vs. 16 CONSOLIDATED GRAPHICS, INC., dba 17 PACIFIC STANDARD PRESS, and AMERICAN LITHOGRAPHERS, INC. 18 Defendants. 19 20 21 22 23 24 25 26 27 28

Complaint Filed: January 13, 2010

CASE NO: 2:10-CV-00109-FCD-KJM

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STIPULATION Plaintiff Pacific Press Publishing Association, Inc. ("Pacific Press") and Defendants

3 Consolidated Graphics, Inc. ("CGX") and American Lithographers, Inc. ("American 4 Lithographers") by and through their counsel of record, hereby stipulate and agree as follows: 5 6 7 8 WHEREAS, Pacific press filed its Complaint on January 14, 2010; WHEREAS, Pacific Press served its Complaint on CGX on February 16, 2010; WHEREAS, Pacific Press its Complaint on American Lithographers on February 16, 2010; WHEREAS, counsel for CGX and American Lithographers and counsel for Pacific Press

9 previously agreed to extend CGX's and American Lithographers' deadlines to answer or otherwise 10 respond to the complaint to May 4, 2010; and 11 WHEREAS, the parties are currently engaged in settlement discussions to settle this matter

12 in its entirety and need additional time to finalize the terms of a full and complete settlement. A 13 settlement would obviate for CGX and American Lithographers to answer and otherwise respond to 14 the complaint, and would also obviate the need for the parties to confer as required by Fed. R. Civ. 15 P. 26 (f) and to submit to the Court a Joint Status Report that includes the Rule 26 (f) discovery 16 plan. To prevent the unnecessary expenditure of resources, counsel for CGX and American 17 Lithographers and counsel for Pacific Press have agreed to extend CGX's and American 18 Lithographers' deadline to answer or otherwise respond to the Complaint to May 31, 2010, and 19 have further agreed to extend the deadline to file the Rule 26 (f) Joint Status Report to June 15, 20 2010 to allow the parties to finalize their settlement agreement. 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 -1CASE NO: 2:10-CV-00109-FCD-KJM

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NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the parties, through

2 their respective counsel, that CGX's and American Lithographers' new deadline to answer or 3 otherwise respond to the Complaint shall be May 31, 2010, and that the parties' deadline to file the 4 Rule 26 (f) Joint Status Report shall be June15, 2010. 5 6 DATED: April 29, 2010 7 8 9 10 11 12 13 DATED: April 29, 2010 14 15 16 17 18 19 20 21 22 23 24 DATED: April 29, 2010 25 26 27 28 -2CASE NO: 2:10-CV-00109-FCD-KJM IT IS SO ORDERED. /s/ Cyril J. Dantchev By: S. Lloyd Smith Kirk M. Nuzum Cyril J. Dantchev Attorneys for Plaintiff, PACIFIC PRESS PUBLISHING ASSOCIATION, INC. BUCHANAN INGERSOLL & ROONEY LLP /s/ Polly Towill By: Polly Towill Moe Keshavarzi Attorneys for Defendants, CONSOLIDATED GRAPHICS, INC. AND AMERICAN LITHOGRAPHERS, INC. SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

_______________________________________ FRANK C. DAMRELL, JR. UNITED STATES DISTRICT JUDGE