Joli Grace, LLC v. Country Visions, Inc.
Filing
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STIPULATION and ORDER signed by Senior Judge William B. Shubb on 10/23/16: HEARING as to 17 Motion to Dismiss continued to 11/28/2016 at 01:30 PM in Courtroom 5 (WBS) before Senior Judge William B. Shubb. (Kaminski, H)
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DOWNEY BRAND LLP
ELIZABETH B. STALLARD (Bar No. 221445)
621 Capitol Mall, 18th Floor
Sacramento, CA 95814-4731
Telephone:
916.444.1000
Facsimile:
916.444.2100
estallard@downeybrand.com
GARNER & GINSBURG, P.A.
W. Michael Garner (MN Bar No. 0274914)
(admitted pro hac vice)
222 South Ninth Street, Suite 2930
Minneapolis, MN 55402
Telephone:
(612) 259-4800
Facsimile:
(612) 259-4810
wmgarner@yourfranchiselawyer.com
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Attorneys for Plaintiff/Counter-Defendants
JOLI GRACE, LLC; STACIE LANCASTER;
ARTHUR LANCASTER; and LOVE GRACE
HOLDINGS, INC.
DOWNEY BRAND LLP
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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JOLI GRACE, LLC, a Louisiana Limited
Liability Company,
Plaintiff,
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JOINT STIPULATION TO CONTINUE
HEARING ON MOTION TO DISMISS
COUNTERCLAIM; [PROPOSED] ORDER
v.
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Case No. 2:16-cv-01138-WBS-EFB
COUNTRY VISIONS, INC., a California
corporation,
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Defendant.
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AND RELATED CROSS-ACTIONS.
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Plaintiff/Counter-Defendants JOLI GRACE, LLC; STACIE LANCASTER; ARTHUR
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LANCASTER; and LOVE GRACE HOLDINGS, INC., and Defendant/Counter-Claimant
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COUNTRY VISIONS, INC. (the “Parties”), by and through their respective counsel of record,
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stipulate as follows:
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1461077.2
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JOINT STIP TO CONTINUE HEARING ON MOTION TO DISMISS COUNTERCLAIM; [PROPOSED] ORDER
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RECITALS
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On October 17, 2016, Plaintiff/Counter-Defendants JOLI GRACE, LLC, STACIE
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LANCASTER, LOVE GRACE HOLDINGS, INC. AND ARTHUR LANCASTER (Counter-
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Defendants) filed a motion to dismiss counterclaim. The motion is currently set for hearing on
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October 31, 2016.
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Counsel for Plaintiff/Counter-Defendants has a scheduling conflict with the current
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hearing date. Defendant/Counter-Claimant is willing to continue the date of the hearing to
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accommodate this scheduling conflict so long as the briefing schedule for the Motion remains
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based on the initial hearing date, and Counter Defendants do not seek to change the November
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14, 2016 hearing date on Defendant’s Motion for a Preliminary Injunction.
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STIPULATION
DOWNEY BRAND LLP
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The Parties stipulate to vacate the hearing date of October 31, 2016, and continue the
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motion hearing to November 28, 2016. The deadline to file any reply papers shall not move and
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shall be based on the original hearing date, and Counter-Defendants will not seek to change the
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hearing date on Defendant’s Motion for a Preliminary Injunction.
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DATED: October 24, 2016
DOWNEY BRAND LLP
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By:
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DATED: October 24, 2016
/s/ Elizabeth B. Stallard
ELIZABETH B. STALLARD
Attorneys for Plaintiff/Counter-Defendants
JOLI GRACE, LLC; STACIE LANCASTER,
ARTHUR LANCASTER; and LOVE GRACE
HOLDINGS, INC.
DLA PIPER LLP
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By:/s/ Robert D. Swanson (as authorized on 10/24/16)
ROBERT D. SWANSON
Attorneys for Defendants/Counter-Claimant
COUNTRY VISIONS, INC.
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1461077.2
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JOINT STIP TO CONTINUE HEARING ON MOTION TO DISMISS COUNTERCLAIM; [PROPOSED] ORDER
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ORDER
Based on the Parties’ stipulation, and good cause appearing therefore, IT IS HEREBY
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ORDERED that the hearing date on the pending motion to dismiss be vacated and continued to
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November 28, 2016, at 1:30 p.m. in Courtroom 5, 14th Floor. The deadline to file any reply shall
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not move and shall be based on the original hearing date.
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IT IS SO ORDERED.
Dated: October 24, 2016
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DOWNEY BRAND LLP
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1461077.2
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JOINT STIP TO CONTINUE HEARING ON MOTION TO DISMISS COUNTERCLAIM; [PROPOSED] ORDER
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