Williams v. EAdgear Holdings USA, Inc., et al
Filing
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STIPULATION AND ORDER TO CONSOLIDATE this action with 3:13-cv-01186 JCS. Signed by Judge Joseph C. Spero on 2/28/14. (klhS, COURT STAFF) (Filed on 2/28/2014)
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Danning Jiang, Esq. (CA BAR No. 196985)
LAW OFFICES OF DANNING JIANG
271 North First Street
San Jose, California 95113
Tel.: (408) 299-0800
Fax: (408) 299-0300
E-mail: djiang@jianglawgroup.com
Attorneys for Plaintiffs EADGEAR, INC., a California
corporation, and GOFUNPLACES, INC., a British Virgin
Islands corporation
Martin Jacek Zurada, Esq. (CA Bar No. 218235)
VENARDI ZURADA, LLP
700 Ygnacio Valley Road, Suite 300
Walnut Creek, CA 94596
Tel.: (415) 637-8483
Fax: (925) 937-3905
E-mail: mzurada@vefirm.com
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Attorney for Defendants RANDAL Williams, an individual;
PROSPERITY FORMULA, LLC, a limited liability
company; JUBIMAX, INC., a British Virgin Islands
corporation; AFFILIATE PRO, Inc., a British Virgin Islands
corporation
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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EADGEAR, INC., a California corporation,
and GOFUNPLACES, INC., a British Virgin
Islands corporation
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Case No. 13-01186 JCS
STIPULATION TO CONSOLIDATE &
[PROPOSED] ORDER
Plaintiffs,
v.
RANDAL WILLIAMS, an individual,
PROSPERITY FORMULA, LLC, a limited
liability company, JUBIMAX LLC, a
limited liability company, JUBIMAX, INC.,
a British Virgin Islands corporation,
AFFILIATE PRO, INC., a British Virgin
Islands corporation, and DOES 1 to 100,
inclusive,
Date:
Time:
Courtroom:
Judge:
February 28, 2013
1:30 p.m.
G
Hon. Joseph C. Spiero
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Defendants.
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STIPULATION & [PROPOSED] ORDER
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The Parties in the above-entitled action submit this STIPULATION TO CONSOLIDATE &
PROPOSED ORDER:
1. Introduction
Before the Court are two separate actions: Williams v. eAdGear, Inc., et al. (Case No: 3:14-cv00504-JCS) [“the Texas Case”] and eAdGear,Inc. v. Williams, et al. (Case No: 3:13-cv-01186JCS) [“the California Case”]. These cases involve the same parties and factual circumstances. In
both cases, the parties are represented by the same counsel. In short, the combined cases represent
a complaint and related cross-complaint. Counsel for both sides have agreed to consolidate the
cases for the sake of efficiency.
2. Brief Procedural History
The Texas Case was initially filed on February 21, 2013 in the Western District of Texas. The
California Case was initially filed on March 15, 2013. Both cases involve the same parties,
factual circumstances, and in both cases the parties are represented by the same counsel.
The Texas Case was transferred to this Court on February 3, 2014. The California Case was
assigned to Hon. Judge Jeffrey S. White on May 15, 2013. On February 11, 2014 the California
Case was referred to Hon. Joseph C. Spiero. Now, both cases which together constitute a
complaint and cross-complaint on the same set of facts, are before this Court.
3. Stipulation to Consolidate
The parties agree to have both actions litigated together before magistrate judge Joseph C. Spero
and stipulate to consolidate this action into Williams v. eAdGear Holdings USA Inc. C 14-00504
JCS.
DATED: February 21, 2014
LAW OFFICES OF DANNING JIANG
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By:
/s/ Danning Jiang_________
Danning Jiang, Esq.
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Attorneys for Plaintiffs
EADGEAR, INC., a California
corporation, and GOFUNPLACES,
INC., a British Virgin Islands
corporation
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DATED: February 21, 2014
VENARDI ZURADA, LLP
By:
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/s/ Martin Jacek Zurada
Martin Jacek Zurada, Esq.
Attorneys for Defendants
RANDAL WILLIAMS, an individual,
PROSPERITY FORMULA, LLC, a
limited liability company, JUBIMAX LLC,
a limited liability company, JUBIMAX,
INC., a British Virgin Islands corporation,
AFFILIATE PRO, INC., a British Virgin
Islands corporation
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STIPULATION & [PROPOSED] ORDER
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[PROPOSED] ORDER
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The above stipulation to consolidate is GRANTED.
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February 28, 2014
NO
UNITED STATESJoseph C. Spero
MAGISTRATE JUDGE
dge
H
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Dated:
R NIA
IT IS SO ORDERED.
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STIPULATION & [PROPOSED] ORDER
C
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