ICE Consulting, Inc. et al v. Jensen

Filing 27

STIPULATION AND ORDER re 26 STIPULATION WITH PROPOSED ORDER re 19 Order on Motion for TRO to Continue Hearing Date filed by Gavin Jensen. Temporary Restraining Order Hearing set for 9/15/2016 01:30 PM.. Signed by Judge Edward M. Chen on 8/17/16. (bpfS, COURT STAFF) (Filed on 8/17/2016)

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HARMEET K. DHILLON (SBN: 207873)
[e-mail]
NITOJ P. SINGH (SBN: 265005)
[e-mail]
DHILLON LAW GROUP INC.
177 Post Street, Suite 700
San Francisco, California 94108
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant Gavin Jensen

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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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ICE CONSULTING, INC. et al.,

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Plaintiffs,

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Case Number: 16-CV-04349-EMC

v.

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STIPULATED REQUEST BY ALL
PARTIES TO CONTINUE THE
HEARING ON PLAINTIFF’S MOTION
FOR PRELIMINARY INJUNCTION
AND ORDER TO SHOW CAUSE ; AND
[PROPOSED] ORDER

GAVIN JENSEN,

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Defendant.

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Stipulated Request to Continue Hearing and Order
21475735.v1

Case No. 16-CV-04349-EMC

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Plaintiffs ICE Consulting, Inc. (“ICE”), Uzair Sattar (“Sattar”), and Derick Needham

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(“Needham”), and Defendant Gavin Jensen (“Jensen”), by and through their respective counsel,

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hereby enter into this Stipulation to continue the hearing on Plaintiff ICE’s Motion for a Preliminary

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Injunction and Order to Show Cause, currently set for hearing on August 18, 2016. The parties seek

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such a continuation so that Defendant Jensen’s counsel, who was only retained on August 16, 2016,

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may adequately prepare for any hearing on this matter, and submit an opposition.

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WHEREAS, on August 3, 2016, Plaintiff ICE filed a Notice of Application and Application

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for a Temporary Restraining Order and Notice of Motion and Motion for Preliminary Injunction and

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Order to Show Cause, with supporting documents (Dkt. No. 6);

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WHEREAS, on August 5, 2016, the Court issued an Order Granting Plaintiff’s Ex Parte

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Application for a Temporary Restraining Order (“Order”) (Dkt. No. 19), which set a hearing on the

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Court’s order to show cause on why a preliminary injunction should not issue for August 18, 2016;

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WHEREAS, pursuant to the Court’s August 5, 2016 Order, Defendant Jensen was required to

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submit any opposition to the Motion by August 12, 2016, and Plaintiff ICE was to submit any reply

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papers by August 15, 2016;
WHEREAS, Defendant Jensen only retained counsel on August 16, 2016, and was unable to

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submit an opposition by the time specified by the Court; and

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WHEREAS, the parties have met and conferred and agree that the August 18, 2016 hearing

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should be continued so that Defendant Jensen’s counsel may have time to prepare for any hearing on

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this matter, and submit an opposition;

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ACCORDINGLY, THE PARTIES HEREBY STIPULATE to the following:

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That Plaintiff ICE’s Motion for a Preliminary Injunction be continued to September 15, 2016,

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at 1:30 p.m., or as soon thereafter as the matter may be heard, in Courtroom 5 on the 17th floor of the

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above-entitled court located at 450 Golden Gate Avenue, San Francisco, California 94102;

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That Defendant Jensen shall file and serve any papers in opposition by September 6, 2016;
and

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That Plaintiff ICE shall file and serve any reply papers by September 9, 2016;

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That pursuant to the Court’s Order, the parties stipulate and Defendant Jensen consents to an
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Stipulated Request to Continue Hearing and Order
21475735.v1

Case No. 16-CV-04349-EMC

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extension of the Temporary Restraining Order to remain in effect through 5:00 p.m. of the day after

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the hearing on the Motion for Preliminary Injunction and Order to Show Cause.

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IT IS SO STIPULATED.
Date: August 16, 2016

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DHILLON LAW GROUP INC.
By: /s/ Nitoj P. Singh
Nitoj P. Singh

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Attorneys for Defendant Gavin Jensen

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Date: August 16, 2016

NOSSAMAN LLP
By: /s/ Veronica M. Gray
Veronica M. Gray
Andrew C. Crane

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Attorneys for Plaintiffs Ice Consulting, Inc.;
Uzair Sattar; and Derick Needham

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ORDER

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PURSUANT TO THE STIPULATION, IT IS SO ORDERED.

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dward
Judge E

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IT IS S

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Hon. Edward M. Chen
United States District Judge

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Stipulated Request to Continue Hearing and Order
21475735.v1

Case No. 16-CV-04349-EMC