Higgins v. Farr Financial Inc. et al

Filing 248

ORDER GRANTING AS MODIFIED 247 Stipulation. Case Management Statement due by 10/21/2011. Case Management Conference set for 10/28/2011 01:30 PM in Courtroom 11, 19th Floor, San Francisco.. Signed by Judge Jeffrey S. White on 9/29/11. (jjoS, COURT STAFF) (Filed on 9/29/2011)

Case3:07-cv-02200-JSW Document247

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Filed09/28/11 Page1 of 3

Norman G. Reece, Jr.
Idaho State Bar No. 3898
NORMAN G. REECE, P.C.
445 West Chubbuck Road, Suite D
Chubbuck, Idaho 83202
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
Pro Hac Vice
Attorneys for Plaintiff

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Howard J. Stein
70 W. Madison St., Suite 2100
Chicago, IL 60602
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorney for Defendant Farr Financial, Inc.

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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HOWARD B. HIGGINS, an individual,
Case No. C 07-02200 JSW

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Plaintiff,

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vs.

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FARR FINANCIAL INC., a California
Corporation, ZENITH INVESTMENT
GROUP LLC, a California Limited
Liability Company, AMAECHI
GEORGE OZOR, an individual, and
JOHN/JANE DOES I-X, individuals or
entities whose identities are unknown,

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STIPULATION AND
PROPOSED ORDER

Defendants.

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_______________________________________________________________________________________________________

STIPULATION AND P ROPOSED ORD ER - Case No. C 07-02200 JSW

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Case3:07-cv-02200-JSW Document247

Defendant, Farr Financial, Inc. (“Farr”) and Plaintiff, Howard B. Higgins

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Filed09/28/11 Page2 of 3

(“Higgins”), by and through their respective attorneys, submit this stipulation, in which
they agree as follows:

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This matter has been resolved as between Higgins and Farr. Counsel for Higgins

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and counsel for Farr are presently preparing a settlement agreement and mutual release.

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Therefore, Farr and Higgins stipulate and jointly request that all pending litigation
deadlines, as well as the pre-trial conference and bench trial, be vacated.

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Good cause exists to grant this stipulation. Submissions prior to the pre-trial

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conference are due filed with the Court on October 3, 2011. However, the parties cannot

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have all the settlement documents signed and dismissal papers filed before that date.

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Therefore, the parties request that they be given until October 7, 2011 to file dismissal

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documents with the Court.
IT IS SO STIPULATED.

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Dated: September 28, 2011

NORMAN G. REECE, P.C.

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By:

/s/ Norman G. Reece, Jr.
NORMAN G. REECE, JR.
Attorney for Plaintiff, Howard B. Higgins
(Pro Hac Vice)

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Dated: September 28, 2011

HOWARD J. STEIN & ASSOC.

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By:

Howard J. Stein
HOWARD J. STEIN
Attorneys for Defendant, Farr Financial, Inc.
(Pro Hac Vice)

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/s/

_______________________________________________________________________________________________________

STIPULATION AND P ROPOSED ORD ER - Case No. C 07-02200 JSW

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Case3:07-cv-02200-JSW Document247

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ORDER

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Good cause appearing, IT IS ORDERED that the stipulation is GRANTED. All
pending litigation deadlines, as well as the pre-trial conference and bench trial, are hereby
vacated. Farr Financial, Inc. and Howard B. Higgins, through their respective counsel,
shall file dismissal papers by October 7, 2011. The Court HEREBY SETS this matter
for a further case management conference at 1:30 p.m. on October 28, 2011 for all parties
IT IS SO ORDERED.
remaining in this action. The parties shall file a further case management conference
statement by no later than October 21, 2011.
IT IS SO ORDERED.
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Dated: September _____, 2011

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__________________________________
HON. JEFFREY S. WHITE
United States District Judge

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_______________________________________________________________________________________________________

STIPULATION AND P ROPOSED ORD ER - Case No. C 07-02200 JSW

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