General Cigar Company Inc. v. Agopian et al

Filing 17

STIPULATION AND ORDER re 16 STIPULATION for Administrative Relief to Continue Deadlines filed by Arbi Agopian, CEO Cigars, Inc., Gray Ash, Inc., James Agopian. Case Management Statement due by 6/11/2013. Initial Case Management Conference set for 6/18/2013 10:00 AM in Courtroom E, 15th Floor, San Francisco. Signed by Judge Elizabeth D Laporte on 5/29/2013. (knm, COURT STAFF) (Filed on 5/30/2013)

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1 2 3 4 5 6 7 8 9 MARTIROSYAN P.C. EDGAR MARTIROSYAN, SBN 260250 emartirosyan@mpclegal.com 16130 Ventura Blvd., Suite 570 Encino, CA 91436 Telephone: (818) 528-8700 Facsimile: (818) 528-8704 Attorney for Defendants, JAMES AGOPIAN, GRAY ASH, INC., ARBI AGHOPIAN, and CEO CIGARS, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ) ) ) Plaintiff, ) ) vs. ) ) JAMES AGOPIAN, an individual; GRAY ) ASH, INC., a California corporation; ) COHIBA CIGAR BOUTIQUE & LOUNGE, ) an unknown business entity; ARBI ) AGHOPIAN, an individual; and CEO ) CIGARS, INC., a California Corporation; ) ) Defendants. ) ) Case No.: CV 13-0840 EDL GENERAL CIGAR COMPANY INC., JOINT AND STIPULATED MOTION AND [PROPOSED] ORDER FOR ADMINISTRATIVE RELIEF TO CONTINUE DEADLINES [Civil L.R. 7-11, 16-2(d)] Judge: Hon. Elizabeth D. Laporte 1 Pursuant to L.R. 7-11, 7-12 and 16-2(b), Plaintiff General Cigar Company Inc. (“General 2 Cigar”) and Defendants James Agopian, Gray Ash, Inc., Arbi Aghopian, and C.E.O. Cigars, Inc. 3 (“Defendants”), by and through their counsel, hereby jointly move the Court for an order 4 continuing deadlines for the Joint Case Management Statement and Rule 26(f) Report and the 5 Initial Case Management Conference each by two (2) weeks. 6 The current deadline for filing the Joint Case Management Statement and Rule 26(f) 7 Report is May 28, 2013, and the Case Management Conference is currently scheduled for June 4, 8 2013, at 10:00 a.m. 9 The parties have been engaged in settlement negotiations over the course of the last two 10 weeks. 11 scheduling conflicts have made it difficult to finalize the agreement before the current Rule 26(f) 12 Report deadline. The parties believe that they will enter into a settlement agreement within the 13 next two weeks. If they are unable to do so within the next two week, then the parties would like 14 to move forward with this action. While the parties have agreed to all material terms of the settlement agreement, 15 Counsel for both parties have met and conferred and agree to continue the current dates 16 as set forth herein, and the agreed-upon continuances would not affect any other aspect of the 17 case schedule. There has been only one prior modification to the dates for the Joint Case 18 Management Statement and Rule 26(f) Report and the Initial Case Management Conference, 19 both of which were moved one week to give the parties an opportunity to finalize settlement 20 negotiations (the Joint Case Management Statement and Rule 26(f) Report was moved from May 21 21, 2013 to May 28, 2013, and the Initial Case Management Conference was moved from May 22 28, 2013 to June 4, 2013). Counsel for both parties agree and stipulate to this request for relief. 23 Accordingly, the parties request that the deadline for filing the Joint Case Management 24 Statement be continued two (2) weeks, from May 28, 2013, to June 11, 2013. The parties further 25 /// 26 /// 27 /// 28 1 request and stipulate that the Initial Case Management Conference be continued from June 4, 2 2013 at 10:00 a.m., to June 18, 2013 at 10:00 a.m. 3 IT IS SO STIPULATED AND AGREED: 4 5 Dated: May 28, 2013. PILLSBURY WINTHROP SHAW PITTMAN LLP 6 7 By /s/ Jenna F. Karadbil Jenna F. Karadbil Attorneys for GENERAL CIGAR COMPANY INC. 8 9 Dated: May 28, 2013. 10 MARTIROSYAN PC 11 By /s/ Edgar Martirosyan Edgar Martirosyan Attorneys for Defendants C.E.O. CIGARS, INC., GRAY ASH, INC., ARBI AGHOPIAN, and JAMES AGOPIAN 12 13 14 15 I, Edgar Martirosyan, hereby attest, pursuant to N.D. Cal. General Order No. 45, that the 16 concurrence to the filing of this document has been obtained from each signatory hereto. 17 Dated: May 28, 2013. 18 MARTIROSYAN PC 19 By /s/ Edgar Martirosyan Edgar Martirosyan Attorneys for Defendants C.E.O. CIGARS, INC., GRAY ASH, INC., ARBI AGHOPIAN, and JAMES AGOPIAN 20 21 22 23 PURSUANT TO STIPULATION, IT IS SO ORDERED. 24 25 26 27 28 May 29, 2013 Dated: _________________ Honorable Elizabeth D. Laporte UNITED STATES MAGISTRATE JUDGE

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