Clifford et al v. Concord Music Group, Inc.

Filing 96

STIPULATION AND ORDER re 95 Second 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 6/19/13. (bpf, COURT STAFF) (Filed on 6/19/2013)

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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
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]

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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
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]

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

DOUGLAS CLIFFORD, STUART COOK,
and PATRICIA FOGERTY,

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SECOND 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,

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Defendant.
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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

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extended for thirty days from June 17, 2013 to July 17, 2013.
SECOND 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 a corresponding
thirty days from June 20, 2013 to July 20, 2013.
This is the second request by the parties to extend these deadlines and this stipulated

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extension is filed so that the parties may finalize a long-form settlement agreement, which would
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supersede the Memorandum of Settlement Agreement signed by the parties on February 13, 2013.
The parties expect this request to be their final one.
Respectfully submitted,

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Dated: June 17, 2013

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WATSON ROUNDS

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By: /s/ Michael Rounds
MICHAEL ROUNDS
Attorneys for Plaintiffs DOUGLAS CLIFFORD,
STUART COOK and PATRICIA FOGERTY

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Dated: June 17, 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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ORDER

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UNITED STATES DISTRICT
COURT JUDGE

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RT

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dwa
Judge E

ER

H

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SECOND STIPULATED REQUEST FOR
ORDER EXTENDING DATE TO FILE
DISMISSAL

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hen

rd M. C

NO

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DERED

O OR
IT IS S

R NIA

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LI

UNIT
ED

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FO

Dated: June ___, 2013

RT
U
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S DISTRICT
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C
_______________________________
TA

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A

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PURSUANT TO STIPUATION, IT IS SO ORDERED

S

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N

C
F
D I S TNO. C T O
CASE R I 3:11-CV-02519-EMC

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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:

June 17, 2013

/s/ Merrilyn Marsh
An Employee of Watson Rounds

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SECOND STIPULATED REQUEST FOR
ORDER EXTENDING DATE TO FILE
DISMISSAL

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CASE NO. 3:11-CV-02519-EMC