El Centro Foods, Inc. v. Food All The Time, Inc. et al

Filing 93

ORDER GRANTING AS MODIFIED: 92 STIPULATION WITH PROPOSED ORDER TO EXTEND TIME TO FILE JOINT CASE MANAGEMENT STATEMENT AND CONTINUE CASE MANAGEMENT CONFERENCE filed by El Centro Foods, Inc. Case Management Statement due by 3/10/2016. Case Management Conference set for 3/17/2016 10:00 AM. Signed by Judge Maria-Elena James on 1/8/2016. (cdnS, COURT STAFF) (Filed on 1/8/2016)

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Milord A. Keshishian, SBN 197835
[e-mail]
MILORD & ASSOCIATES, P.C.
2049 Century Park East, Suite 3850
Los Angeles, California 90067
Tel [phone]
Fax [phone]
Attorneys for Plaintiff
EL CENTRO FOODS, INC.

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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MILORD & ASSOCIATES, PC
2049 Century Park East, Suite 3850
Los Angeles, CA 90067
[phone]

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)
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Plaintiff,
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vs.
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FOOD ALL THE TIME, INC., dba Mr. )
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Pizza Man, VICTOR M. PEREZ, an
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individual, RAYMOND KLEIN, an
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individual and DOES 1-10,
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Defendants.
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EL CENTRO FOODS, INC., a
California Corporation,

Case No.: CV 09-04106 MEJ
STIPULATION TO EXTEND TIME
TO FILE JOINT CASE
MANAGEMENT STATEMENT
AND CONTINUE CASE
MANAGEMENT CONFERENCE;
[PROPOSED] ORDER THEREON

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-1STIPULATION TO EXTEND TIME TO FILE JOINT CASE MANAGEMENT STATEMENT AND CONTINUE
CASE MANAGEMENT CONFERENCE – Case No. CV 09-04106 MEJ

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WHEREAS, El Centro Foods, Inc., Food All The Time, Inc. dba Mr. Pizza Man,

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Victor Perez, and Raymond Klein (collectively “parties”) executed a settlement

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agreement, but consideration for the settlement was not timely received and was returned

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for insufficient funds.

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WHEREAS, the Court granted Plaintiff’s request to place the matter back on

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active calendar, ordered a Joint Case Management Statement to be filed by October 30,

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2014, and calendared a Case Management Conference on November 6, 2014, at 10:00

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a.m.
WHEREAS, the Court granted parties’ request to extend the submission deadline

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for the Joint Case Management Statement to January 7, 2016, and continue the Case

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MILORD & ASSOCIATES, PC
2049 Century Park East, Suite 3850
Los Angeles, CA 90067
[phone]

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Management Conference to January 14, 2016, at 10:00 a.m.

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WHEREAS, the parties continue to engage in good faith discussions to possibly

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resolve this matter and not to unnecessarily cause delay with the Court, the parties request

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the Court to extend the deadline to file the Joint Case Management Statement and to

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continue the Case Management Conference;

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THEREFORE the parties, by and through their respective attorneys, hereby

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stipulate, subject to the approval of the Court, to extend the submission deadline for the

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Joint Case Management Statement to March 10, 2016, and continue the Case Management

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Conference to March 17, 2016.

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Dated: January 7, 2016
/s/ Milord A. Keshishian
Milord A. Keshishian, Esq.
MILORD & ASSOCIATES, P.C.
Attorneys for Plaintiff
El Centro Foods, Inc.

/s/ Otto Lee
Otto Lee, Esq.
INTELLECUTAL PROPERTY LAW GROUP, LLP
Attorneys for Defendants
Food All the Time, Inc., Victor Perez, and
Raymond Klein

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-2STIPULATION TO EXTEND TIME TO FILE JOINT CASE MANAGEMENT STATEMENT AND CONTINUE
CASE MANAGEMENT CONFERENCE – Case No. CV 09-04106 MEJ

Attestation Pursuant to L.R. 5-1

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I hereby attest that all other signatories listed, and on whose behalf the filing is
submitted, concur in the filing’s content and have authorized the filing.

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Dated: January 7, 2016

Milord A. Keshishian

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/s/ Milord A. Keshishian

Dated: January 8, 2016

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So Ordered: _____________________________
United States Magistrate Judge

MILORD & ASSOCIATES, PC
2049 Century Park East, Suite 3850
Los Angeles, CA 90067
[phone]

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-3STIPULATION TO EXTEND TIME TO FILE JOINT CASE MANAGEMENT STATEMENT AND CONTINUE
CASE MANAGEMENT CONFERENCE – Case No. CV 09-04106 MEJ