Tat Tohumculuk A.S. v. H. J. Heinz Company, et al
Filing
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STIPULATION AND ORDER signed by Senior Judge William B. Shubb on 11/22/2013 CONTINUING the deadline for Defendants to file a responsive pleading to the Second Amended Complaint to 1/3/2014; CONTINUING the Initial Scheduling Conference to 1/6/2014 at 02:00 PM in Courtroom 5 (WBS) before Senior Judge William B. Shubb. (Michel, G)
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David S. Reidy (SBN 225904)
dreidy@reedsmith.com
Andrew Amoroso (SBN 274673)
aamoroso@reedsmith.com
REED SMITH LLP
101 Second Street, Suite 1800
San Francisco, CA 94105-3659
Telephone:
+1 415 543 8700
Facsimile:
+1 415 391 8269
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REED SMITH LLP
A limited liability partnership formed in the State of Delaware
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Michael T. Scott
(admitted pro hac vice)
mscott@reedsmith.com
REED SMITH LLP
2500 One Liberty Place
1650 Market Street
Philadelphia, PA 19103
Telephone:
+1 215 851 8100
Facsimile:
+1 215 851 1420
Attorneys for Defendant
H.J. Heinz Company, L.P. and HeinzSeed, an
unincorporated division of H.J. Heinz Company,
L.P.
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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TAT TOHUMCULUK A. S., a Turkish company,
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Case 2:13-cv-00773-WBS-KJN
FOURTH STIPULATION AND
[PROPOSED] ORDER TO CONTINUE
INITIAL STATUS CONFERENCE
Plaintiff,
v.
H.J. HEINZ COMPANY, L.P., a Pennsylvania
Limited Partnership registered to do business in
California, and HEINZSEED, an unincorporated
division of H.J. HEINZ COMPANY, L.P,
Current Hearing Scheduled:
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December 23, 2013
2 p.m.
5, 14th Floor
Compl. Filed:
Defendants.
Date:
Time:
Courtroom:
April 19, 2013
Honorable William B. Shubb
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2:13-cv-00773-WBS-KJN
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FOURTH STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL STATUS CONFERENCE
US_ACTIVE-114226947.2-007043-60088
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STIPULATION
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Plaintiffs TAT Tohumculuk A.S. (“Plaintiff”) and Defendants H.J. Heinz Company, L.P.,
and Heinzseed, an unincorporated division of H.J. Heinz Company, L.P. (collectively, “Defendants”)
(collectively, the “Parties”) hereby submit, through their undersigned counsel of record, the
following Stipulation and Proposed Order:
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WHEREAS, on November 14, 2013, this Court entered its Memorandum and Order re
Motion to Dismiss (Dkt. 32) granting in part and denying in part Defendants’ motion to dismiss
Plaintiff’s First Amended Complaint, and granting Plaintiff until December 4, 2013, to file a Second
Amended Complaint;
REED SMITH LLP
A limited liability partnership formed in the State of Delaware
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WHEREAS, Plaintiff intends to file a Second Amended Complaint on or before December 4,
2013;
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WHEREAS, since the response to the Second Amended Complaint would be due during the
holidays, the Parties hereby agree and stipulate that Defendants’ response to the Second Amended
Complaint shall be due no later than January 3, 2014;
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WHEREAS, the Status Conference in the above action is currently scheduled for December
23, 2013;
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WHEREAS, the Parties agree that good cause exists to continue the Status Conference
currently scheduled on December 23, 2013, to a date after Defendants respond to the Second
Amended Complaint, and further request such a continuance to avoid a conflict between the
currently scheduled Status Conference and scheduled end-of-year holidays for the counsel for both
parties; and
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WHEREAS, counsel for Plaintiff and Defendants stipulate to move the Status Conference
hearing to January 6, 2014, when the parties are both mutually available, or to a date thereafter at the
Court’s convenience;
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///
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2:13-cv-00773-WBS-KJN
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FOURTH STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL STATUS CONFERENCE
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THEREFORE, IT IS HEREBY STIPULATED between counsel for Defendants and counsel
for Plaintiff that:
The deadline for Defendants to file a responsive pleading to the Second
Amended Complaint shall be January 3, 2014; and
The Status Conference currently scheduled for December 23, 2013 at 2:00
p.m. is continued to January 6, 2014 at 2:00 p.m., or a date thereafter at the
Court’s convenience.
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SO STIPULATED.
REED SMITH LLP
A limited liability partnership formed in the State of Delaware
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DATED: November 22, 2013
ANASTASSIOU & ASSOCIATES
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By /s/ Effie F. Anastassiou
Effie F. Anastassiou
Attorneys for Plaintiff
TAT TOHUMCULUK A.S.
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DATED: November 22, 2013
REED SMITH LLP
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By
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/s/ David S. Reidy
David S. Reidy
Attorneys for Defendant
H.J. Heinz Company, L.P., sued erroneously as “H.J.
Heinz Company” and HeinzSeed, an unincorporated
division of H.J. Heinz Company, L.P.
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2:13-cv-00773-WBS-KJN
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FOURTH STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL STATUS CONFERENCE
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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 deadline for Defendants to file a responsive pleading to the Second
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Amended Complaint shall be January 3, 2014, and the Scheduling Conference currently scheduled
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for December 23, 2013 at 2:00 p.m. is continued to January 21, 2014 at 2:00 p.m. A Joint Status
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Report shall be filed no later than January 7, 2014.
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SO ORDERED:
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REED SMITH LLP
A limited liability partnership formed in the State of Delaware
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Dated: November 22, 2013
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2:13-cv-00773-WBS-KJN
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FOURTH STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL STATUS CONFERENCE
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