Clifford et al v. Concord Music Group, Inc.

Filing 94

STIPULATION AND ORDER EXTENDING DATE TO FILE DISMISSAL re 93 Stipulation, filed by Douglas Clifford, Stuart Cook, Patricia Fogerty. Signed by Judge Edward M. Chen on 5/16/13. (bpf, COURT STAFF) (Filed on 5/16/2013)

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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: [phone]
Facsimile: 415-243-0226
Email: [e-mail]
Email: [e-mail]
Attorneys for Plaintiffs
DOUGLAS CLIFFORD, STUART COOK, and PATRICIA FOGERTY
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: [phone]
FAX: [phone]
[e-mail]
[e-mail]
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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Plaintiffs,
-vs-

Case No. 3:11-cv-02519-EMC
STIPULATED REQUEST FOR
ORDER EXTENDING DATE TO
FILE DISMISSAL AND/OR
NOTICE REINSTITUTING CASE

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CONCORD MUSIC GROUP, INC. a Delaware
corporation,
Defendant.
IT IS HEREBY stipulated by and between Plaintiffs, DOUGLAS CLIFFORD, STUART

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COOK, and PATRICIA FOGERTY, and Defendant, CONCORD MUSIC GROUP, INC., by and
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between their attorneys of record, that the dates set by which to file a dismissal (Doc. #91) be
STIPULATED REQUEST FOR ORDER
EXTENDING DATE TO FILE DISMISSAL
CASE NO. 3:11-CV-02519-EMC

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extended thirty-two days from May 16, 2013 to June 17, 2013.
It is also stipulated that the conditional dismissal date (Doc. #92) be extended thirty days
from May 21, 2013 to June 20, 2013.

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This is the first request by the parties to extend these deadlines and is filed so that the
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parties may finalize a long-form settlement agreement, which would supersede the Memorandum
of Settlement Agreement signed by the parties on February 13, 2013.

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Respectfully submitted,

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Dated: May 15, 2013
WATSON ROUNDS
By: /s/ Michael Rounds
MICHAEL ROUNDS
Attorneys for Plaintiffs DOUGLAS CLIFFORD,
STUART COOK and PATRICIA FOGERTY

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Dated: May 15, 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 Plaintiffs CONCORD MUSIC GROUP, INC.

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PURSUANT TO STIPUATION, IT IS SO ORDERED

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Dated: May ___, 2013

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ERED

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T IS SO

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STIPULATED REQUEST FOR ORDER
EXTENDING DATE TO FILE DISMISSAL

Case No. 3:11-cv-02519-EMC

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FO

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_______________________________
UNITED STATES DISTRICT d M. Chen
COURT JUDGE Judge Edwar

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CERTIFICATE OF SERVICE
The undersigned certifies that, on this date, she/he caused this document to be
electronically filed with the Clerk of Court using the CM/ECF system, which will send
notification of filing to counsel of record for each party.

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Dated: May 15, 2013

/s/ Jeff Tillison
An Employee of Watson Rounds

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STIPULATED REQUEST FOR ORDER
EXTENDING DATE TO FILE DISMISSAL

Case No. 3:11-cv-02519-EMC

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