Clifford et al v. Concord Music Group, Inc.
Filing
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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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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
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Attorneys for Plaintiffs
DOUGLAS CLIFFORD, STUART COOK, and PATRICIA FOGERTY
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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
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Attorneys for Defendant
CONCORD MUSIC GROUP, INC.
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
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DOUGLAS CLIFFORD, STUART COOK,
and PATRICIA FOGERTY,
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Case No. 3:11-cv-02519-EMC
FOURTH STIPULATED REQUEST
FOR ORDER EXTENDING DATE
TO FILE DISMISSAL AND/OR
NOTICE REINSTITUTING CASE
Plaintiffs,
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-vsCONCORD MUSIC GROUP, INC. a Delaware
corporation,
Defendant.
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IT IS HEREBY stipulated by and between Plaintiffs, DOUGLAS CLIFFORD, STUART
COOK, and PATRICIA FOGERTY, and Defendant, CONCORD MUSIC GROUP, INC., by and
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between their attorneys of record, that the date set by which to file a dismissal (Doc. #91) be
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extended from August 31, 2013 to September 30, 2013.
FOURTH STIPULATED REQUEST FOR
ORDER EXTENDING DATE TO FILE
DISMISSAL
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CASE NO. 3:11-CV-02519-EMC
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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
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unexpected illness of one of the participants required the rescheduling of the settlement
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conference from August 21, 2013 to September 4, 2013. This stipulated extension is filed so that
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the parties may finalize a long-form settlement agreement through a settlement conference with
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Magistrate-Judge Corley, which would supersede the Memorandum of Settlement Agreement
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signed by the parties on February 13, 2013. The parties expect this request to be their final one.
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Respectfully submitted,
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Dated: August 22, 2013
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WATSON ROUNDS
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By: /s/ Michael D. Rounds
MICHAEL D. ROUNDS
Attorneys for Plaintiffs DOUGLAS CLIFFORD,
STUART COOK and PATRICIA FOGERTY
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Dated: August 22, 2013
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LAW OFFICES OF ROBERT S. BESSER
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By: /s/ Robert S. Besser
ROBERT S. BESSER
Attorneys for Defendant CONCORD MUSIC GROUP, INC.
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PURSUANT TO STIPUATION, IT IS SO ORDERED
Dated: August ___, 2013
UNITED STATES DISTRICT
COURT JUDGE
n
M. Che
Edward
Judge
NO
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ER
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FOURTH STIPULATED REQUEST FOR
ORDER EXTENDING DATE TO FILE
DISMISSAL
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R NIA
VED
APPRO
_______________________________
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UNIT
ED
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S DISTRICT
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ORDER
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C
OF
D I S3:11-CV-02519-EMC
CASE NO. T R I C T
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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
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electronic mail through the United States District Court’s CM/ECF system.
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DATED August 22, 2013
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/s/ Jeff Tillison
Employee of Watson Rounds, P.C.
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FOURTH STIPULATED REQUEST FOR
ORDER EXTENDING DATE TO FILE
DISMISSAL
-3-
CASE NO. 3:11-CV-02519-EMC
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