Clifford et al v. Concord Music Group, Inc.

Filing 98

STIPULATION AND ORDER re 97 STIPULATION WITH PROPOSED ORDER THIRD 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 7/17/13. (bpf, COURT STAFF) (Filed on 7/17/2013)

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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]

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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: [phone]
FAX: [phone]
[e-mail]
[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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DOUGLAS CLIFFORD, STUART COOK,
and PATRICIA FOGERTY,

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Case No. 3:11-cv-02519-EMC
THIRD 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 July 17, 2013 to August 31, 2013.
THIRD 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 July
20, 2013 to August 31, 2013.
This is the third 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 through a
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settlement conference with Magistrate-Judge Corley, which would supersede the Memorandum of

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Settlement Agreement signed by the parties on February 13, 2013. The parties expect this request

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to be their final one.

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Respectfully submitted,

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Dated: July 16, 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: July 16, 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

ORD
T IS SO

ERED

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_______________________________
UNITED STATES DISTRICT
COURT JUDGE
en
d M. Ch
e Edwar
Judg

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Dated: July ___, 2013

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NO

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THIRD STIPULATED REQUEST FOR
ORDER EXTENDING DATE TO FILE
DISMISSAL

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

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CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing, THIRD
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 July 16, 2013

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/s/ Jeff Tillison
Employee of Watson Rounds, P.C.

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THIRD STIPULATED REQUEST FOR
ORDER EXTENDING DATE TO FILE
DISMISSAL

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