Rajala v. Sonoma County Go Local Cooperative, Incorporated et al

Filing 76

STIPULATION AND ORDER re 75 STIPULATION WITH PROPOSED ORDER TO EXTEND DEADLINE TO FILE DISPOSITIVE MOTIONS filed by Sustaining Technologies, LLC, Sonoma County Go Local Cooperative, Incorporated. Signed by Judge Jon S. Tigar on June 7, 2016. (wsn, COURT STAFF) (Filed on 6/7/2016)

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Craig M. Stainbrook, Calif. State Bar #160876
E-mail: [e-mail]
STAINBROOK & STAINBROOK, LLP
412 Aviation Boulevard, Suite H
Santa Rosa, California 95403
707.578.9333 phone
707.578.3133 fax

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Attorneys for Defendants,
Sonoma County Go Local Cooperative,
Incorporated and Sustaining Technologies, LLC

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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Kelley Rajala,

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Plaintiff,

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vs.
Sonoma County Go Local Cooperative,
Incorporated, Et Al.,

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JOINT STIPULATION TO
EXTEND DEADLINE TO FILE
DISPOSITIVE MOTIONS
[PROPOSED] ORDER
Honorable Jon S. Tigar

Defendants

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Case No.: 15-CV-00442-JST

Sonoma County Go Local Cooperative,
Incorporated and Sustaining Technologies,
LLC,
vs.

Counterclaimants,

Rajala, Kelley, an individual, and
Local Works, Flexible Purpose Corporation,
A California Corporation,
Counterclaim Defendants.
JOINT STIP. TO EXTEND DEADLINE TO FILE DISPOSITIVE MOTIONS
Case. No. 15-CV-442-JST

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Defendants/Counterclaimants, Sonoma County Go Local Cooperative,

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Incorporated and Sustaining Technologies, LLC, and Plaintiffs/Counterclaim

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Defendants, Kelley Rajala and Local Works, Flexible Purpose Corporation, by and

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through their respective counsel, jointly request that the Court grant a three-week

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extension of time by which the parties must file dispositive motions. Should the

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Court grant this request, the deadline to file dispositive motions would be moved
from its current date of June 10, 2016, to July 1, 2016. The grounds for this request
are as follows:
1.

Pursuant to Court order, the parties engaged in an early neutral

evaluation on April 29, 2016, before evaluator Daralyn Durie of Durie Tangri
Lemley Roberts & Kent, in San Francisco.
2.

The ENE process led to an agreement to settle the dispute, and a term

sheet was executed by both parties setting out the material terms of the agreement.
3.

The Term Sheet recites that the agreement will be memorialized in a

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final settlement agreement, and that any disputes regarding the finalization of the

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agreement will be submitted to Daralyn Durie for resolution via binding

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arbitration.

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4.

Since the date of the ENE, the parties, through counsel, have engaged

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(and continue to engage) in a good faith effort to conclude a final settlement

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agreement. However, there remain a few provisions over which the parties have

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yet to agree.

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5.

Should the parties be unable to finalize the settlement agreement

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before June 10, 2016, the parties will cooperate in scheduling a binding arbitration

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with Ms. Durie at a time convenient for all parties and counsel.

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6.

Accordingly, for the reasons set forth above, the parties agree that in

the interests of fairness, in the interests of resolving the matter without further need
of court or neutral evaluator intervention, to preserve the parties’ respective rights
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JOINT STIPULATION AND ORDER TO EXTEND ADR DEADLINE

Case. No. 15-CV-442-JST

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to file dispositive motions should the need continue to exist, the parties respectfully

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request that the Court grant a three-week extension of time to file dispositive

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motions in this case.

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7.

No other dates in the current schedule under the Amended Scheduling

Order [Dkt 54], including dates for filing pre-trial briefs and motions, or trial, need
be disturbed.
Respectfully Submitted,

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Dated: May 27, 2016

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STAINBROOK & STAINBROOK, LLP
By: /s/ Craig M. Stainbrook

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Craig M. Stainbrook
[e-mail]

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Attorneys for Defendants/Counterclaimants
Sonoma County Go Local Cooperative,
Incorporated and Sustaining Technologies,
LLC

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Dated: May 27, 2016

ONE LLP

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By: /s/ Joanna Ardalan
________________________________
Joanna Ardalan
[e-mail]
Attorneys for Plaintiff/Counterdefendants
Kelley Rajala and Local Works, Flexible
Purpose Corporation

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JOINT STIPULATION AND ORDER TO EXTEND ADR DEADLINE

Case. No. 15-CV-442-JST

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ORDER

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SHOWN, IT IS ORDERED that the deadline for filing dispositive motions is
extended to July 1, 2016.

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NO

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DERED
SO OR
IT IS
_________________________________________
Honorable Jon S. Tigar,
U.S. District Court iJudge
. T ga r
ge J o n S
Jud

R NIA

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Dated: June 7, 2016

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UNIT
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S DISTRICT
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PURSUANT TO STIPULATION, AND GOOD CAUSE HAVING BEEN

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N

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OF

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JOINT STIPULATION AND ORDER TO EXTEND ADR DEADLINE

Case. No. 15-CV-442-JST