California Republican Party v. Asian American Small Business Political Action Committee

Filing 12

STIPULATION AND ORDER signed by District Judge Troy L. Nunley on 4/23/2015 ORDERING the defendants to respond to the 1 Complaint for Trademark Infringement by 5/4/2015. (Michel, G.)

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Louis E. Kempinsky (CA State Bar No. 90068)
[e-mail]
Laura D. Castner (CA State Bar No. 172362)
[e-mail]
KEMPINSKY LAW LTD.
11111 Santa Monica Blvd., Suite 1700
Los Angeles, CA 90025
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant Asian American
Small Business Political Action Committee

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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Case No. 2:15-CV-00505-TLN-AC

CALIFORNIA REPUBLICAN PARTY,

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STIPULATION FOR THIRD EXTENSION
OF TIME FOR DEFENDANT TO
RESPOND TO COMPLAINT; ORDER
THEREON

Plaintiff,
vs.

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ASIAN AMERICAN SMALL BUSINESS
POLITICAL ACTION COMMITTEE,

Defendant.

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Stipulation and Order To Further Extend
Time To Respond To Complaint

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Plaintiff California Republican Party and Defendant Asian American Small Business Political

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Action Committee, through their respective counsel of record, hereby stipulate that Defendant shall

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have a fourteen-day extension of time up through, and including, May 4, 2015, in which to plead or

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otherwise respond to the complaint. This is the third such extension sought. Defendant and Plaintiff

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previously stipulated to two extensions of ten days each, the second of which extended until April 20,

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2015, the deadline for Defendant to plead or otherwise respond to the complaint.
The Court’s approval of this third stipulated extension is respectfully requested as the parties

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appear close to reaching a settlement resolving all claims and disputes involved in this lawsuit, which

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asserts four claims against Defendant for trademark infringement. The parties contemplate that the

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settlement agreement will also include provisions intended to avoid future disputes of the kind giving

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rise to this lawsuit.

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The parties believe that they can, by May 4, 2015, complete the negotiation, documentation,

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and execution of a definitive agreement, which would then result in the dismissal of this lawsuit. The

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total extension of time to which the parties have stipulated in all three stipulations is thirty-four (34)

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Stipulation and Order To Further Extend
Time To Respond To Complaint

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days from the date on which Defendant’s response to the complaint was originally due. This is the last

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stipulation the parties will file respecting the deadline to respond to the complaint.

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Dated: April 17, 2015

DHILLON LAW GROUP INC.

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By/s/ Harmeet K. Dhillon (as authorized on 4/17/15)
Harmeet K. Dhillon
Attorneys for Plaintiff

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Dated: April 17, 2015

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KEMPINSKY LAW LTD.
By/s/ Louis E. Kempinsky
Louis E. Kempinsky
Attorneys for Defendant

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IT IS SO ORDERED.
Dated: April 23, 2015

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Troy L. Nunley
United States District Judge

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Stipulation and Order To Further Extend
Time To Respond To Complaint

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