General Cigar Company Inc. v. Agopian et al
Filing
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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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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
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Plaintiff,
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vs.
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JAMES AGOPIAN, an individual; GRAY )
ASH, INC., a California corporation;
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COHIBA CIGAR BOUTIQUE & LOUNGE, )
an unknown business entity; ARBI
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AGHOPIAN, an individual; and CEO
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CIGARS, INC., a California Corporation;
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Defendants.
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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
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Pursuant to L.R. 7-11, 7-12 and 16-2(b), Plaintiff General Cigar Company Inc. (“General
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Cigar”) and Defendants James Agopian, Gray Ash, Inc., Arbi Aghopian, and C.E.O. Cigars, Inc.
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(“Defendants”), by and through their counsel, hereby jointly move the Court for an order
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continuing deadlines for the Joint Case Management Statement and Rule 26(f) Report and the
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Initial Case Management Conference each by two (2) weeks.
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The current deadline for filing the Joint Case Management Statement and Rule 26(f)
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Report is May 28, 2013, and the Case Management Conference is currently scheduled for June 4,
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2013, at 10:00 a.m.
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The parties have been engaged in settlement negotiations over the course of the last two
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weeks.
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scheduling conflicts have made it difficult to finalize the agreement before the current Rule 26(f)
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Report deadline. The parties believe that they will enter into a settlement agreement within the
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next two weeks. If they are unable to do so within the next two week, then the parties would like
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to move forward with this action.
While the parties have agreed to all material terms of the settlement agreement,
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Counsel for both parties have met and conferred and agree to continue the current dates
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as set forth herein, and the agreed-upon continuances would not affect any other aspect of the
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case schedule. There has been only one prior modification to the dates for the Joint Case
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Management Statement and Rule 26(f) Report and the Initial Case Management Conference,
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both of which were moved one week to give the parties an opportunity to finalize settlement
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negotiations (the Joint Case Management Statement and Rule 26(f) Report was moved from May
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21, 2013 to May 28, 2013, and the Initial Case Management Conference was moved from May
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28, 2013 to June 4, 2013). Counsel for both parties agree and stipulate to this request for relief.
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Accordingly, the parties request that the deadline for filing the Joint Case Management
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Statement be continued two (2) weeks, from May 28, 2013, to June 11, 2013. The parties further
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request and stipulate that the Initial Case Management Conference be continued from June 4,
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2013 at 10:00 a.m., to June 18, 2013 at 10:00 a.m.
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IT IS SO STIPULATED AND AGREED:
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Dated: May 28, 2013.
PILLSBURY WINTHROP SHAW PITTMAN LLP
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By /s/ Jenna F. Karadbil
Jenna F. Karadbil
Attorneys for GENERAL CIGAR COMPANY INC.
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Dated: May 28, 2013.
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MARTIROSYAN PC
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By /s/ Edgar Martirosyan
Edgar Martirosyan
Attorneys for Defendants C.E.O. CIGARS, INC.,
GRAY ASH, INC., ARBI AGHOPIAN, and JAMES
AGOPIAN
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I, Edgar Martirosyan, hereby attest, pursuant to N.D. Cal. General Order No. 45, that the
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concurrence to the filing of this document has been obtained from each signatory hereto.
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Dated: May 28, 2013.
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MARTIROSYAN PC
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By /s/ Edgar Martirosyan
Edgar Martirosyan
Attorneys for Defendants C.E.O. CIGARS, INC.,
GRAY ASH, INC., ARBI AGHOPIAN, and JAMES
AGOPIAN
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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May 29, 2013
Dated: _________________
Honorable Elizabeth D. Laporte
UNITED STATES MAGISTRATE JUDGE
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