Clifford et al v. Concord Music Group, Inc.

Filing 101

STIPULATION AND ORDER re 100 STIPULATION WITH PROPOSED ORDER FOURTH STIPULATED REQUEST FOR ORDER EXTENDING DATE TO FILE DISMISSAL AND/OR NOTICE REINSTITUTING CASE filed by Douglas Clifford, Stuart Cook, Patricia Fogerty. Signed by Judge Edward M. Chen on 8/26/13. (bpf, COURT STAFF) (Filed on 8/26/2013)

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1 2 3 4 5 MICHAEL D. ROUNDS (CA Bar #133972) ADAM K. YOWELL (CA Bar #273661) WATSON ROUNDS One Embarcadero Center Suite 4100 San Francisco, California 94111 Phone: 415-243-4090 Facsimile: 415-243-0226 Email: mrounds@watsonrounds.com Email: ayowell@watsonrounds.com 6 7 Attorneys for Plaintiffs DOUGLAS CLIFFORD, STUART COOK, and PATRICIA FOGERTY 8 9 10 11 12 ROBERT S. BESSER, State Bar No. 46541 CHRISTOPHER CHAPIN, State Bar No. 112608 LAW OFFICES OF ROBERT S. BESSER 1221 Second Street Suite 300 Santa Monica, California 90401 TEL: (310) 394-6611 FAX: (310) 394-6613 rsbesser@aol.com christopherchapin@aol.com 13 14 Attorneys for Defendant CONCORD MUSIC GROUP, INC. 15 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 16 17 18 DOUGLAS CLIFFORD, STUART COOK, and PATRICIA FOGERTY, 19 Case No. 3:11-cv-02519-EMC FOURTH STIPULATED REQUEST FOR ORDER EXTENDING DATE TO FILE DISMISSAL AND/OR NOTICE REINSTITUTING CASE Plaintiffs, 20 21 22 23 -vsCONCORD MUSIC GROUP, INC. a Delaware corporation, Defendant. 24 25 26 IT IS HEREBY stipulated by and between Plaintiffs, DOUGLAS CLIFFORD, STUART COOK, and PATRICIA FOGERTY, and Defendant, CONCORD MUSIC GROUP, INC., by and 27 between their attorneys of record, that the date set by which to file a dismissal (Doc. #91) be 28 extended from August 31, 2013 to September 30, 2013. FOURTH STIPULATED REQUEST FOR ORDER EXTENDING DATE TO FILE DISMISSAL -1- CASE NO. 3:11-CV-02519-EMC 1 2 3 It is also stipulated that the conditional dismissal date (Doc. #92) be extended from August 31, 2013 to September 30, 2013. This is the fourth request by the parties to extend these deadlines and is made because an 4 unexpected illness of one of the participants required the rescheduling of the settlement 5 6 conference from August 21, 2013 to September 4, 2013. This stipulated extension is filed so that 7 the parties may finalize a long-form settlement agreement through a settlement conference with 8 Magistrate-Judge Corley, which would supersede the Memorandum of Settlement Agreement 9 signed by the parties on February 13, 2013. The parties expect this request to be their final one. 10 11 Respectfully submitted, 12 Dated: August 22, 2013 13 WATSON ROUNDS 14 By: /s/ Michael D. Rounds MICHAEL D. ROUNDS Attorneys for Plaintiffs DOUGLAS CLIFFORD, STUART COOK and PATRICIA FOGERTY 15 16 17 Dated: August 22, 2013 18 LAW OFFICES OF ROBERT S. BESSER 19 By: /s/ Robert S. Besser ROBERT S. BESSER Attorneys for Defendant CONCORD MUSIC GROUP, INC. 21 S PURSUANT TO STIPUATION, IT IS SO ORDERED Dated: August ___, 2013 UNITED STATES DISTRICT COURT JUDGE n M. Che Edward Judge NO 26 RT 27 ER H 28 FOURTH STIPULATED REQUEST FOR ORDER EXTENDING DATE TO FILE DISMISSAL -2- R NIA VED APPRO _______________________________ 26 LI 25 UNIT ED 24 S DISTRICT TE C TA RT U O 23 ORDER FO 22 A 20 C OF D I S3:11-CV-02519-EMC CASE NO. T R I C T N 1 2 3 4 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing, FOURTH STIPULATED REQUEST FOR ORDER EXTENDING DATE TO FILE DISMISSAL AND/OR NOTICE REINSTITUTING CASE, will be served upon counsel of record via 5 electronic mail through the United States District Court’s CM/ECF system. 6 7 8 DATED August 22, 2013 9 /s/ Jeff Tillison Employee of Watson Rounds, P.C. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 FOURTH STIPULATED REQUEST FOR ORDER EXTENDING DATE TO FILE DISMISSAL -3- CASE NO. 3:11-CV-02519-EMC

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