Williams v. EAdgear Holdings USA, Inc., et al

Filing 146

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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1 2 3 4 5 6 7 8 9 10 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 11 12 13 14 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 15 16 UNITED STATES DISTRICT COURT 17 NORTHERN DISTRICT OF CALIFORNIA 18 19 20 EADGEAR, INC., a California corporation, and GOFUNPLACES, INC., a British Virgin Islands corporation 21 22 23 24 25 26 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 27 Defendants. 28 1 STIPULATION & [PROPOSED] ORDER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 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 18 By: /s/ Danning Jiang_________ Danning Jiang, Esq. 19 Attorneys for Plaintiffs EADGEAR, INC., a California corporation, and GOFUNPLACES, INC., a British Virgin Islands corporation 20 21 22 23 DATED: February 21, 2014 VENARDI ZURADA, LLP By: 24 /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 25 26 27 28 2 STIPULATION & [PROPOSED] ORDER 1 [PROPOSED] ORDER 2 The above stipulation to consolidate is GRANTED. 3 February 28, 2014 NO UNITED STATESJoseph C. Spero MAGISTRATE JUDGE dge H ER 9 FO RT 8 Ju LI 7 A Dated: R NIA IT IS SO ORDERED. 6 UNIT ED 5 ISTRIC ES D TC AT T RT U O S 4 N F D IS T IC T O R 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 STIPULATION & [PROPOSED] ORDER C

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