SOURCiS, Inc. v. Bravo Development Group, LLC

Filing 47

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 12/14/15 ordering as to 25 MOTION to QUASH Or, in the Alternative, Motion to Modify Subpoena ( Motion Hearing continued to 1/21/2016 at 10:00 AM in Courtroom 25 (KJN) before Magistrate Judge Kendall J. Newman.) (Plummer, M)

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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 Non-Party Witness
BRAVO DEVELOPMENT GROUP, LLC

UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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law corporation

weintraub tobin chediak coleman grodin

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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 [PROPOSED] ORDER
RE: CONTINUANCE OF HEARING DATE
ON NON-PARTY WITNESS BRAVO
DEVELOPMENT GROUP, LLC’S MOTION
TO QUASH, OR IN THE ALTERNATIVE,
MOTION TO MODIFY SUBPOENA
Complaint Filed: July 23, 2015
FAC Filed: September 18, 2015

Plaintiff SOURCIS, INC. (“Plaintiff”) and Non-Party Witness Bravo Development
Group, LLC (“Bravo LLC”), by and through their counsel of record, hereby submit the
following Stipulation and [Proposed] Order re: Continuance of Hearing Date on NonParty Witness Bravo LLC’s Motion to Quash, or in the alternative, Motion to Modify
Subpoena (“Motion to Quash”) (Dckt. # 25):

{1987664.DOC;}

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Stip. & (Proposed) Order Continuing
Hearing on Motion to Quash

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1.

WHEREAS, on November 6, 2015, plaintiff served Non-Party Witness Bravo

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LLC with a subpoena duces tecum requiring the production of responsive documents by

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10 a.m. on November 16, 2015;

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2.

WHEREAS, on November 16, 2015, Non-Party Witness Bravo LLC filed its

Motion to Quash, and scheduled the hearing on the motion for December 17, 2015;

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3.

WHEREAS, the parties to this action have reached an agreement to settle all

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disputes between them, including the claims asserted in this action, and are in the

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process of preparing a formal settlement agreement;

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4.

WHEREAS, plaintiff and Bravo LLC believe that it is in the interests of the

parties and the Court to continue the hearing on Bravo LLC’s Motion to Quash so that the

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settlement documents can be finalized and a stipulation for dismissal of this action filed

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with the Court.

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THEREFORE, plaintiff and Bravo LLC hereby stipulate and request the Court to issue
an Order that:

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1.

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The hearing on Bravo LLC’s Motion to Quash is continued to January 21,

2016.

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law corporation

weintraub tobin chediak coleman grodin

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IT IS SO STIPULATED.
Dated: December 10, 2015

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BURGOYNE LAW GROUP
By:

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Dated: December 10, 2015

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/s/ - James Kachmar
James Kachmar

Attorneys for Non-Party Witness Bravo Development
Group, LLC

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WEINTRAUB TOBIN CHEDIAK COLEMAN GRODIN
Law Corporation
By:

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

///

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{1987664.DOC;}

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Stip. & (Proposed) Order Continuing
Hearing on Motion to Quash

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IT IS SO ORDERED.

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Dated: December 14, 2015

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law corporation

weintraub tobin chediak coleman grodin

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{1987664.DOC;}

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Stip. & (Proposed) Order Continuing
Hearing on Motion to Quash