Chelsea, LLC v. Regal Stone, Ltd. et al

Filing 142

STIPULATION AND ORDER Order Extending Hanjin Shipping's Time to File and Serve a Response to Plaintiffs' Verified Second Amended Class Action Complaint. Signed by Judge Samuel Conti on 9/29/08. (tdm, COURT STAFF) (Filed on 9/30/2008)

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FLYNN, DELICH & WISE LLP

Erich P. Wise/State Bar No. 63219 Aleksandrs E. Drumalds/State Bar No. 237101 FLYNN, DELICH & WISE LLP One World Trade Center, Suite 1800 Long Beach, California 90831-1800 Telephone: [phone] Facsimile: [phone] James B. Nebel/State Bar No. 69626 Conte C. Cicala/State Bar No. 173554 FLYNN, DELICH & WISE LLP One California Street, Suite 350 San Francisco, California Telephone: [phone] Facsimile: [phone] Attorneys for Defendant HANJIN SHIPPING CO., LTD. UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

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ATTORNEYS AT LAW One World Trade Center, Suite 1800 Long Beach, California 90831-1800 [phone]

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Chelsea, LLC, Mark Russo, and Allen ) CASE NO.: CV-07-5800 SC ) 15 Loretz, individually and on behalf of all others similarly situated, ) STIPULATION OF PLAINTIFFS 16 ) AND DEFENDANT HANJIN Plaintiffs, 17 ) SHIPPING CO., LTD. TO FURTHER EXTEND THE TIME ) 18 FOR FILING AND SERVICE OF A vs. ) RESPONSE TO PLAINTFFS' 19 ) VERIFIED SECOND AMENDED 20 Regal Stone, Ltd., Hanjin Shipping ) CLASS ACTION COMPLAINT; Co., Ltd., Synergy Maritime, Ltd., ) ORDER THEREON 21 Fleet Management, Ltd., and John ) 22 Cota, In Personam; M/V Cosco ) [Civil Local Rule 6-1(b)] Busan, their engine, tackle, ) 23 equipment, appurtenances, freights, ) 24 and cargo, In Rem, ) 25 ) Defendants. ) 26 ______________________________
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-1STIPULATION OF PLAINTIFFS AND DEFENDANT HANJIN SHIPPING CO., LTD. TO FURTHER EXTEND THE TIME FOR FILING AND SERVICE OF A RESPONSE TO PLAINTFFS' VERIFIED SECOND AMENDED CLASS ACTION COMPLAINT; ORDER THEREON

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FLYNN, DELICH & WISE LLP

TO THE COURT AND ALL COUNSEL OF RECORD: IT IS HEREBY STIPULATED by and between plaintiffs CHELSEA, LLC, MARK RUSSO, and ALLEN LORETZ ("Plaintiffs") and defendant HANJIN SHIPPING CO., LTD, ("Hanjin"), through their respective counsel of record, that the time for Hanjin to file and serve a response to Plaintiffs' Verified Second Amended Class Action Complaint is further extended by an additional seven (7) days. Defendant Hanjin will file and serve its response to Plaintiffs' Verified Second Amended Class Action Complaint no later than Friday, October 3, 2008. The Court has approved previous requests by Plaintiffs and Hanjin to

10 extend the time for Hanjin to respond to Plaintiffs' Verified Second Amended
ATTORNEYS AT LAW One World Trade Center, Suite 1800 Long Beach, California 90831-1800 [phone]

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This stipulation for a further extension of time is not entered into for

13 purposes of delay, but to permit defendant Hanjin to continue its investigation, to 14 address the new allegations contained in Plaintiffs' Verified Second Amended 15 Class Action Complaint, and to allow defendant Hanjin to formulate a proper 16 response. 17 18 19 20 21 22 23 24 25 26 27 28

IT IS SO STIPULATED AND AGREED. Dated: September 26, 2008 AUDET & PARTNERS, LLP By: /s/ William M. Audet (as authorized on 9/26/08) William M. Audet Attorney for Plaintiff CHELSEA, LLC, MARK RUSSO, and ALLEN LORETZ Dated: September 26, 2008 FLYNN, DELICH & WISE LLP By: /s/ Erich P. Wise Erich P. Wise Attorney for Defendant HANJIN SHIPPING CO., LTD
-2STIPULATION OF PLAINTIFFS AND DEFENDANT HANJIN SHIPPING CO., LTD. TO FURTHER EXTEND THE TIME FOR FILING AND SERVICE OF A RESPONSE TO PLAINTFFS' VERIFIED SECOND AMENDED CLASS ACTION COMPLAINT; ORDER THEREON

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FLYNN, DELICH & WISE LLP

ORDER Based on the foregoing Stipulation, IT IS HEREBY ORDERED that the time for defendant HANJIN SHIPPING CO., LTD to file and serve a response to the Verified Second Amended Class Action Complaint of plaintiffs CHELSEA, LLC, MARK RUSSO, and ALLEN LORETZ is further extended by an additional seven days (7) days. Defendant Hanjin is ordered to file and serve its response to Plaintiffs' Verified Second Amended Class Action Complaint no later than Friday, October 3, 2008. PURSUANT TO STIPULATION, IT IS SO ORDERED.
UNIT ED

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ATTORNEYS AT LAW One World Trade Center, Suite 1800 Long Beach, California 90831-1800 [phone]

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September 29, 2008 Dated: ____________________

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-3STIPULATION OF PLAINTIFFS AND DEFENDANT HANJIN SHIPPING CO., LTD. TO FURTHER EXTEND THE TIME FOR FILING AND SERVICE OF A RESPONSE TO PLAINTFFS' VERIFIED SECOND AMENDED CLASS ACTION COMPLAINT; ORDER THEREON

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________________________________ ERED HON. SAMUELOCONTI O RD IT IS S UNITED STATES DISTRICT JUDGE
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