Tat Tohumculuk A.S. v. H. J. Heinz Company, et al

Filing 20

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 6/27/2013 ORDERING Initial Scheduling Conference RESET for 9/30/2013 at 02:00 PM in Courtroom 5 (WBS) before Senior Judge William B. Shubb; a joint status report shall be filed no later than 9/16/2013. (Waggoner, D)

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Effie F. Anastassiou, Esq. (SBN 96279)
ANASTASSIOU & ASSOCIATES
242 Capitol Street
Post Office Box 2210
Salinas, California 93902
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff,
TAT TOHUMCULUK A. S.

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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TAT TOHUMCULUK A. S., a Turkish )
company,
)
)
Plaintiff,
)
)
v.
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)
H.J. HEINZ COMPANY, a Pennsylvania )
corporation registered to do business in )
California, and HEINZSEED, a division of )
H.J. HEINZ COMPANY
,
)
)
Defendants.
)
____________________________________ )

CASE NO. 2:13-cv-00773-WBS-KJN

STIPULATION AND [PROPOSED] ORDER
TO CONTINUE STATUS CONFERENCE
Current Hearing Information:
Date:
July 22, 2013
Time:
2:00 p.m.
Courtroom: 5

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WHEREAS, on April 22, 2013, this Court issued its Order Re: Status (Pretrial Scheduling)
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Conference which set the Status Conference in the above referenced matter for July 22, 2013 at 2:00
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p.m.;1
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WHEREAS, on May 30, 2013 Defendants H. J. HEINZ COMPANY L.P., erroneously sued as
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"H. J. Heinz Company" and HEINZSEED, an unincorporated division of H.J. HEINZ COMPANY L.P.
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(collectively, "Defendants") filed their Motion of Defendant to Dismiss Complaint (the “Motion”) of
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Plaintiff TAT TOHUMCULUK A. S. (“Plaintiff”);2
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WHEREAS, the Motion is scheduled to be heard on August 12, 2013 at 2:00 p.m.;
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ECF No. 5.

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ECF No. 12.

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Tat Tohumculuk v. Heinz Seed
Case No. 2:13-cv-00773-W BS-KJNC

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S TIPU LATIO N AN D O RD ER TO
C O N TIN UE S TATU S C O N FEREN CE

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WHEREAS, counsel for Defendants and for Plaintiff believe that good cause exists to continue

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the status conference in order to preserver the time and resources of the Court and all parties until the

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pleadings at issues are resolved;

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WHEREAS, counsel for Defendants and for Plaintiff wish to stipulate to move the Status

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Conference hearing to a date after the Motion is heard to allow time for the Court to rule on the Motion;

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THEREFORE, IT IS HEREBY STIPULATED between counsel for Plaintiff and counsel for

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Defendants that:

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1.

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The Status Conference currently scheduled for July 22, 2013 at 2:00 p.m. is continued to

a date after August 31, 2013;
SO STIPULATED.

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Dated: June 26, 2013

ANASTASSIOU & ASSOCIATES

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By:

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/s/ Effie F. Anastassiou
Effie F. Anastassiou, Esq.
Attorneys for Plaintiff,
TAT TOHUMCULUK A. S.

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Dated: June 26, 2013

REED SMITH LLP

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By:

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/s/ Michael T. Scott
Michael T. Scott, Esq.
Attorneys for Defendants,
H. J. HEINZ COMPANY L.P., erroneously sued as
"H. J. Heinz Company" and HEINZSEED, an
unincorporated division of H.J. HEINZ
COMPANY, L.P.

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Tat Tohumculuk v. Heinz Seed
Case No. 2:13-cv-00773-W BS-KJNC

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S TIPU LATIO N AN D O RD ER TO
C O N TIN UE S TATU S C O N FEREN CE

ORDER

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Appearing that good cause exists pursuant to the foregoing stipulation of the parties, IT IS

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HEREBY ORDERED that the Status Conference currently scheduled for July 22, 2013 is continued to:

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September 30, 2013 at 2:00 p.m. in Courtroom 5. A Joint Status Report shall be filed no later than

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September 16, 2013.

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Dated: June 27, 2013
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Tat Tohumculuk v. Heinz Seed
Case No. 2:13-cv-00773-W BS-KJNC

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S TIPU LATIO N AN D O RD ER TO
C O N TIN UE S TATU S C O N FEREN CE