World Surveillance Group Inc v. La Jolla Cove Investors, Inc.

Filing 11

STIPULATION AND ORDER REGARDING UPCOMING EX PARTE MOTION HEARING AND TIME TO RESPOND TO COMPLAINT re 10 STIPULATION WITH PROPOSED ORDER. Motion Hearing re 3 MOTION for Temporary Restraining Order set for 10/16/2013 02:00 PM in Courtroom 2, 17t h Floor, San Francisco before Hon. William H. Orrick. Response/Opposition due 21 days prior to hearing date; Reply due 14 days prior to hearing date. Response to Complaint by answer or motion due October 30, 2013. Signed by Judge William H. Orrick on 08/12/2013. (jmdS, COURT STAFF) (Filed on 8/12/2013)

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Craig S. Miller (State Bar No. No. 139682)
William S. Weisberg (State Bar No. 146284)
WEISBERG & MILLER
654 Sacramento Street, Third Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Plaintiff
World Surveillance Group, Inc.

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LAW OFFICES OF

WEISBERG & MILLER

654 SACRAMENTO STREET  THIRD FLOOR  SAN FRANCISCO  CA 94111
PHONE 4152967070 FAX 4152967060

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO DIVISION

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WORLD SURVEILLANCE GROUP INC.,
a Delaware Corporation,
Plaintiff,

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vs.
LA JOLLA COVE INVESTORS, INC.,
a California corporation,

Case No. 3:13-cv-03455 (WHO)
STIPULATION REGARDING UPCOMING
EX PARTE MOTION HEARING AND
TIME TO RESPOND TO COMPLAINT;
ORDER
Current Hearing Date: September 4, 2013
Time: 2:00 pm
Courtroom: 2

DOES 1-30,
Defendants.

STIPULATION
Plaintiff World Surveillance Group Inc. (“WSGI”) and Defendant La Jolla Cove
Investors, Inc. (“La Jolla”), by and through their counsel of record, hereby file the following
stipulation regarding the upcoming September 4, 2013 hearing of Plaintiff’s Motion for
Temporary Restraining Order and Order to Show Cause Regarding Preliminary Injunction
(“Motion”) and the time for La Jolla to respond to WSGI’s Complaint:

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World Surveillance Group v. La Jolla Cove Investors, Inc.
U.S. District Court – No. District of CA (San Francisco) – Case CV 13-03455 (WHO)
STIPULATION RE : HEARING AND RESPONSE TO COMPLAINT

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WHEREAS both WSGI and La Jolla have agreed that private mediation of this matter

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may be able to resolve the disputes between the parties in this case without further Court

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involvement; and

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WHEREAS both WSGI and La Jolla have agreed that any private mediation should take

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place prior to a hearing and/or briefing on the scheduled Motion and La Jolla’s response to

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WSGI’s Complaint;

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LAW OFFICES OF

WEISBERG & MILLER

654 SACRAMENTO STREET  THIRD FLOOR  SAN FRANCISCO  CA 94111
PHONE 4152967070 FAX 4152967060

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NOW, THEREFORE, WSGI and La Jolla stipulate to the following:
1. That the hearing of the Motion currently scheduled for September 4, 2013 at 2:00
pm, shall be continued to October 16, 2013 at 2:00 pm;
2. That La Jolla’s Opposition to WSGI’s Motion will be due twenty-one (21) days
prior to the October 16, 2013 hearing date;
3. That WSGI’s Reply to La Jolla’s Opposition will be due fourteen (14) days prior
to the October 16, 2013 hearing date;
4. That the due date for La Jolla’s response to WSGI’s Complaint, by answer or
motion, shall be extended until October 30, 2013;
5. That, in the meantime, the parties each will do everything reasonably in their
power to ensure that the mediation takes place within thirty (30) days;
IT IS SO STIPULATED.
The parties hereby request that the Court affirm this stipulation by signing it pursuant to
Local Rule 7-12.
WEISBERG & MILLER,

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Dated: August 6, 2013
By:

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World Surveillance Group v. La Jolla Cove Investors, Inc.
U.S. District Court – No. District of CA (San Francisco) – Case CV 13-03455 (WHO)
STIPULATION RE : HEARING AND RESPONSE TO COMPLAINT

/s/ Craig S. Miller
Craig S. Miller,
Attorneys for Plaintiff
World Surveillance Group Inc.

DLA PIPER LLP (US),

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Dated: August 6, 2013
By:

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/s/ Roy McDonald
Roy McDonald,
Attorneys for Defendant
La Jolla Cove Investors, Inc.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: August 12, 2013

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__________________________________
The Hon. District Judge William H. Orrick

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LAW OFFICES OF

WEISBERG & MILLER

654 SACRAMENTO STREET  THIRD FLOOR  SAN FRANCISCO  CA 94111
PHONE 4152967070 FAX 4152967060

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Page 3 of 3
World Surveillance Group v. La Jolla Cove Investors, Inc.
U.S. District Court – No. District of CA (San Francisco) – Case CV 13-03455 (WHO)
STIPULATION RE : HEARING AND RESPONSE TO COMPLAINT