Kristen Lazzara v. Randa Accessories Leather Goods, LLC et al

Filing 32

STIPULATION AND ORDER re: 31 : Case Management Conference CONTINUED to 2/3/2016 09:30 AM in Courtroom 5, 17th Floor, San Francisco. Signed by Judge Edward M. Chen on 1/27/2016. (afmS, COURT STAFF) (Filed on 1/27/2016)

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Mary Josephine Shea (SBN 113222)
SHEA LAW OFFICES
1814 Franklin Street, Suite 800
Oakland, CA 94612
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiff, KRISTEN LAZZARA
CHERYL D. ORR (SBN 143196)
[e-mail]
RAMON A. MIYAR (SBN 284990)
[e-mail]
DRINKER BIDDLE & REATH LLP
50 Fremont Street, 20th Floor
San Francisco, CA 94105-2235
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendants
RANDA ACCESSORIES LEATHER GOODS,
LLC; MARKET CONNECT GROUP, INC.
Additional counsel listed on following page.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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KRISTEN LAZZARA,

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Plaintiff,
v.
RANDA ACCESSORIES LEATHER
GOODS, LLC, a Delaware Limited
Liability Company; MARKET CONNECT
GROUP, INC., a Delaware Corporation;
and Does 1 through 20, inclusive,

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Case No. 3:15-cv-03233-EMC
JOINT STIPULATION TO CONTINUE
JANUARY 28, 2016 CASE MANAGEMENT
CONFERENCE AND

Current Date: January 28, 2016
Time: 9:30 a.m.
Courtroom: 5

Defendant.

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JOINT STIP TO CONTINUE JANUARY 28, 2016
CMC; [PROPOSED] ORDER
84401829.1

CASE NO. 3:15-CV-03233-EMC

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KATE S. GOLD (SBN 156117)
[e-mail]
PHILIPPE A. LEBEL (SBN 274032)
[e-mail]
DRINKER BIDDLE & REATH LLP
1800 Century Park East
Suite 1500
Los Angeles, CA 90067-1517
Telephone:
[phone]
Facsimile:
[phone]
Counsel for Defendants
RANDA ACCESSORIES LEATHER GOODS,
LLC; MARKET CONNECT GROUP, INC.

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JOINT STIP TO CONTINUE JANUARY 28, 2016
CMC; [PROPOSED] ORDER
84401829.1

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CASE NO. 3:15-CV-03233-EMC

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Plaintiff Kristen Lazzara (“Plaintiff”), on the one hand, and Defendants Randa

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Accessories Leather Goods, LLC and Market Connect Group, Inc. (collectively, “Defendants”),

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on the other hand,1 hereby agree as follows:

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WHEREAS, the Court set a case management conference in the above-captioned matter
for January 28, 2016 at 9:30 a.m. in Courtroom 5;

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WHEREAS, lead counsel for Defendants is unable to attend in person on January 28,
2016; and

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WHEREAS, the clerk of the Court informed counsel for Defendants that the Court would
be amenable to a continuance of the case management conference so that lead counsel for
Defendants could appear in person.

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Accordingly, the Parties stipulate and agree as follows:

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1.

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continued to February 3, 2016 at 9:30 a.m. in Courtroom 5; and

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2.

Lead counsel for each of the Parties shall appear in person at the February 3, 2016

case management conference.

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The case management conference presently set for January 28, 2016 shall be

IT IS SO STIPULATED.
Dated: January 27, 2016

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SHEA LAW OFFICES
By: /s/ Mary Josephine Shea
Mary Josephine Shea

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Attorneys for Plaintiff
KRISTEN LAZZARA

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Dated: January 27, 2016

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DRINKER BIDDLE & REATH LLP
By: /s/ Cheryl D. Orr
Cheryl D. Orr

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Attorneys for Defendants
RANDA ACCESSORIES LEATHER
GOODS, LLC; MARKET CONNECT
GROUP, INC.

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Collectively, Plaintiff and Defendants are referred to herein as the “Parties.”

JOINT STIP TO CONTINUE JANUARY 28, 2016
CMC; [PROPOSED] ORDER
84401829.1

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CASE NO. 3:15-CV-03233-EMC

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[PROPOSED] ORDER
Upon consideration of Plaintiff Kristen Lazzara’s and Defendants Randa Accessories

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Leather Goods, LLC and Market Connect Group, Inc. Joint Stipulation to Continue January 28,

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2016 Case Management Conference, and for good cause shown, the Court hereby ORDERS as

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follows:

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1.

The case management conference presently set for January 28, 2016 shall be

continued to February 3, 2016 at 9:30 a.m. in Courtroom 5; and
2.

Lead counsel for each of the Parties shall appear in person at the February 3, 2016

case management conference.
IT IS SO ORDERED.

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27th
DATED: January ____, 2016

__________________________________
Hon. Edward M. Chen

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JOINT STIP TO CONTINUE JANUARY 28, 2016
CMC; [PROPOSED] ORDER
84401829.1

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CASE NO. 3:15-CV-03233-EMC

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SIGNATURE CERTIFICATION

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I am the ECF User whose identification and password are being used to file the foregoing

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JOINT STIPULATION TO CONTINUE JANUARY 28, 2016 CASE MANAGEMENT

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CONFERENCE AND [PROPOSED] ORDER. Pursuant to Civil Local Rule 5.1 of the Northern

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District of California, I hereby attest that the content of this document is acceptable to Mary

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Josephine Shea, counsel to Plaintiff , and that I have obtained Ms. Shea’s permission to affix her

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electronic signature to this document.

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Dated:

January 27, 2016

DRINKER BIDDLE & REATH LLP

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By: /s/ Cheryl D. Orr
Cheryl D. Orr
Kate S. Gold
Philippe A. Lebel
Ramon A. Miyar

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Attorneys for Defendants
RANDA ACCESSORIES LEATHER
GOODS, LLC; MARKET CONNECT
GROUP, INC.

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JOINT STIP TO CONTINUE JANUARY 28, 2016
CMC; [PROPOSED] ORDER
84401829.1

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CASE NO. 3:15-CV-03233-EMC