Grow Scene Productions, LLC v. Haze Consulting, Inc. et al

Filing 75

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 11/1/2012 ORDERING that dispositional documents be filed by 11/30/2012. (Michel, G)

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ALAN KORN, SBN 167933
LAW OFFICE OF ALAN KORN
1840 Woolsey Street
Berkeley, California 94703
Ph. [phone]; Fax: [phone]
Attorney for Plaintiff Grow Scene Productions, LLC

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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GROW SCENE PRODUCTIONS, LLC, a
California Limited Liability Company

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Plaintiff,

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v.
HAZE CONSULTING, INC., a California
Corporation, TROY W. GOINGS, an individual
dba GET ME GOINGS PRODUCTIONS,
SAMUEL TRUJILLO, an individual, ROBERT
PYNE, an individual, SARELI MARKETING,
INC., a California Corporation and MARLO
JORDON, an individual.
Defendants.

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CASE No. 10-CV-02573-KJN
STIPULATION AND [PROPOSED]
ORDER RE: EXTENSION OF TIME
TO FILE DISPOSITIONAL
DOCUMENTS

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Pursuant to Rule 143 of the Civil Local Rules of the United States District Court, Eastern

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District of California, Plaintiff Grow Scene Productions, LLC (“Plaintiff”) on the one hand, and

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Defendants Haze Consulting, Inc., Troy W. Goings, Samuel Trujillo, Robert Pyne and Marlo

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Jordon (“Defendants”) on the other hand, hereby stipulate as follows:
WHEREAS, Plaintiff forwarded a proposed written settlement agreement (the “Settlement

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Agreement”) to Defendants on August 3, 2012 based on the terms and conditions that were

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verbally entered into the record at the July 25, 2012 Settlement Conference in the above matter;

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and

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WHEREAS Plaintiff has received no response concerning the proposed Settlement
Agreement from Defendants Haze Consulting, Inc. Samuel Trujillo, Robert Pyne and Marlo
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STIPULATION AND [PROPOSED] ORDER RE: EXTENSION OF TIME TO FILE
DISPOSITIONAL DOCUMENTS
CASE NO.: CASE No. 10-CV-02573-KJN

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Jordon despite repeated email requests; and
WHEREAS Plaintiff’s counsel was recently advised by Defendant Goings that he is “fine”

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with, and intends to sign and return, a copy of the proposed Settlement Agreement; and
WHEREAS the Court issued a Minute Order dated July 26, 2012 requiring the parties to

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file dispositional documents by no later than August 31, 2012; and

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WHEREAS this Court on September 5, 2012 previously granted the parties Stipulation and

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[Proposed] Order requiring dispositive documents to be filed by no later than September 28, 2012;

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and on October 1, 2012 again granted the parties Stipulation and [Proposed] Order requiring

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dispositive documents to be filed by no later than October 31, 2012; and;
WHEREAS, it is evident that the parties require additional time to negotiate and finalize

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their settlement agreement; and
WHEREAS, Plaintiff and Defendants agree that the extension of time to file dispositional

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documents will not alter the date of any other event or deadline already fixed by the Court;

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NOW THEREFORE, Plaintiff and Defendants, by and through their respective

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undersigned counsel or representing themselves in pro per, hereby stipulate as follows:
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The time for the parties to file dispositional documents shall be extended to and

including November 30, 2012.

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SO STIPULATED.

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DATED: October 29, 2012

LAW OFFICE OF ALAN KORN

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By:

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/Alan Korn/
Alan Korn
Attorneys for Plaintiff
GROW SCENE PRODUCTIONS, LLC

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///

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///

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///

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STIPULATION AND [PROPOSED] ORDER RE: EXTENSION OF TIME TO FILE
DISPOSITIONAL DOCUMENTS
CASE NO.: CASE No. 10-CV-02573-KJN

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DATED: October 29, 2012

GEORGE W.M. MULL

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By:

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/George Mull/ (as authorized October 29, 2012)
George Mull
Attorneys for Defendants
HAZE CONSULTING, INC., SAMULE TRUJILLO,
ROBERT PYNE and MARLO JORDON

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DATED: October 29, 2012

TROY GOINGS

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By:

/Troy Goings (as authorized on October 29, 2012)
Troy Goings
Defendant, in Pro Per

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STIPULATION AND [PROPOSED] ORDER RE: EXTENSION OF TIME TO FILE
DISPOSITIONAL DOCUMENTS
CASE NO.: CASE No. 10-CV-02573-KJN

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[PROPOSED] ORDER

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Pursuant to the foregoing Stipulation, IT IS HEREBY ORDERED that

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dispositional documents in the above matter shall be filed by no later than November

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30, 2012.

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Following issuance of this order, the undersigned will have extended the

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parties’ deadline to file dispositional documents three separate times. (Dkt. Nos. 71,

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73.) While the undersigned grants the foregoing Stipulation, the undersigned hereby

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informs the parties that absent extraordinary circumstances he will be disinclined to

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grant additional similar stipulations in the future. Should the parties request yet

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another extension, the undersigned may issue an order requiring the delaying party

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(or parties) to show cause why they should not be sanctioned for acting in bad faith

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and/or delaying the closure of this case after having agreed to settle the matter during

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the settlement conference in July of 2012.

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Date: 11/1/2012

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_____________________________________
KENDALL J. NEWMAN
UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND [PROPOSED] ORDER RE: EXTENSION OF TIME TO FILE
DISPOSITIONAL DOCUMENTS
CASE NO.: CASE No. 10-CV-02573-KJN

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PROOF OF SERVICE

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I, Alan Korn, declare as follows:

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I am employed by the Law Office of Alan Korn in Alameda County, California. I

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am over the age of eighteen (18) years; my business and employment address is 1840 Woolsey

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Street, Berkeley, California 94703.

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On October 30, 2012, I served a true copy of the following:

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STIPULATION AND [PROPOSED] ORDER RE: EXTENSION OF TIME
TO FILE DISPOSITIONAL DOCUMENTS
on the parties listed below in this action by causing them to be mailed via U.S. Mail, postage
prepaid, to the addressees at the following address:

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Troy W. Goings
5801 Revelstock Drive
Sacramento, CA 95842

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In addition, as this case is subject to the United States District Court for the Eastern

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District of California ECF program, upon the filing of the above-entitled document(s) an

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automatically generated email message was generated by the Court’s electronic filing system and

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sent to the address(es) shown below and constitutes service on the receiving party

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George W.M. Mull, Esq.
1415 L Street, Suite 100
Sacramento, CA 95814

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I declare under penalty of perjury of the law of the State of California that the
foregoing is true and correct. Executed on October 30, 2012, at Berkeley, California.

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/Alan Korn/

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ad4mc0d

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STIPULATION AND [PROPOSED] ORDER RE: EXTENSION OF TIME TO FILE
DISPOSITIONAL DOCUMENTS
CASE NO.: CASE No. 10-CV-02573-KJN