SOURCiS, Inc. v. Bravo Development Group, LLC

Filing 20

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 11/3/15: HEARING as to 15 MOTION to DISMISS, 14 MOTION to STRIKE RESET for 12/10/2015 at 02:00 PM in Courtroom 2 (TLN) before District Judge Troy L. Nunley. (Kaminski, H)

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law corporation

weintraub tobin chediak coleman grodin

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Henry M. Burgoyne, III, State Bar No. 203748
BURGOYNE LAW GROUP
870 Market Street, Suite 985
San Francisco, California 94102
[phone] – Tel.
[phone] – Facsimile
Attorneys for Plaintiff SOURCIS, Inc.
James Kachmar, State Bar No. 216781
weintraub tobin chediak coleman grodin
law corporation

400 Capitol Mall, 11th Floor
Sacramento, CA 95814
[phone] – Main
[phone] – Facsimile
Attorneys for Defendant
BRAVO DEVELOPMENT GROUP, INC.
Robert D. Swanson, State Bar No. 162816
Michael E. Chase, State Bar No. 214506
BOUTIN JONES INC.
555 Capitol Mall, Suite 1500
Sacramento, CA 95814-4603
Attorneys for Defendant DEREK C. DECKER

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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SOURCIS, INC, a California corporation,

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Plaintiff,
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v.
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BRAVO DEVELOPMENT GROUP, INC., a )
California corporation; et al.,
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Defendants.
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Case No.: 2:15-cv-01588-TLN-KJN
STIPULATION AND ORDER RE:
CONTINUANCE OF HEARING DATE ON
DEFENDANT BRAVO DEVELOPMENT
GROUP, INC.’S MOTION TO DISMISS
AND ANTI-SLAPP MOTION
Complaint Filed: July 23, 2015
FAC Filed: September 18, 2015

Plaintiff SOURCIS, INC. (“Plaintiff”), Defendant Bravo Development Group, Inc.

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Stip. & Order Continuing
Hearing on Bravo’s Motions

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(“Bravo”) and Defendant Derek C. Decker (“Decker”), by and through their counsel of

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record, hereby submit the following Stipulation and [Proposed] Order re: Continuance of

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Hearing Date on Defendant Bravo’s Motions:

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1.

WHEREAS, on October 12, 2015, Bravo filed its Motion to Dismiss (Dckt.

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#15) and Motion to Strike Lawsuit Against Public Policy (“Anti-SLAPP Motion”) (Dckt. #14)

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which were set for hearing on November 19, 2015;

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2.

WHEREAS, counsel for Plaintiff was in trial through October 27, 2015 and

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has requested that the hearing date be continued to allow Plaintiff additional time to

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prepare its oppositions to the motions;

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3.

Dismiss and Anti-SLAPP Motion to December 10, 2015;
4.

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a.

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Plaintiff’s Oppositions to the Motion to Dismiss and Anti-SLAPP

Motion shall be filed on or before November 20, 2015;

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WHEREAS, given the intervening Thanksgiving holidays, the parties agree to

modify the briefing schedule as follows:

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law corporation

weintraub tobin chediak coleman grodin

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WHEREAS, Bravo is agreeable to continuing the hearing on its Motion to

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Any reply briefs by Bravo shall be filed on or before December 2,

2015.
5.

WHEREAS, the parties agree that discovery commenced after the joint

F.R.C.P. Rule 26(f) conference currently as held on October 28, 2015.

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THEREFORE, the parties hereto stipulate and request the Court to issue an Order that:
1.

The hearing on Bravo’s Motion to Dismiss and Anti-SLAPP Motion be

continued to December 10, 2015;

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2.

Any oppositions to such motions be filed on or before November 20, 2015;

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3.

Any reply briefs in support of said motions be filed on or before December

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2, 2015; and
4.

Discovery commenced after the parties’ joint F.R.C.P. Rule 26(f) conference

on October 28, 2015.

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Stip. & Order Continuing
Hearing on Bravo’s Motions

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IT IS SO STIPULATED.
Dated: November 3, 2015

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BURGOYNE LAW GROUP
By:

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Dated: November 3, 2015

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WEINTRAUB TOBIN CHEDIAK COLEMAN GRODIN
Law Corporation
By:

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Dated: November 3, 2015

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BOUTIN JONES INC.

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/s/ - Michael E. Chase
Robert D. Swanson
Michael E. Chase

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By:

Attorneys for Defendant Derek C. Decker

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law corporation

weintraub tobin chediak coleman grodin

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/s/ - James Kachmar
James Kachmar
Attorneys for Defendant Bravo Development
Group, Inc.

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/s/ - Henry M. Burgoyne, III
Henry M. Burgoyne, III
Attorneys for Plaintiff Sourcis, Inc.

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IT IS SO ORDERED.

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Dated: November 3, 2015

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Troy L. Nunley
United States District Judge

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Stip. & Order Continuing
Hearing on Bravo’s Motions