Sustainable Ranching Partners, Inc. v. Bering Pacific Ranches Limited et al

Filing 30

STIPULATION AND ORDER re 29 STIPULATION AND [PROPOSED] ORDER Re: Continuing Initial Case Management Conference and Related Dates filed by Sustainable Ranching Partners, Inc.. Case Management Statement due by 10/23/2017. Initial Case Management Conference set for 11/1/2017 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on August 31, 2017. (wsn, COURT STAFF) (Filed on 8/31/2017)

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William C. Reeves - 183878
MORALES FIERRO & REEVES
2151 Salvio Street, Suite 280
Concord, CA 94520
Telephone: [phone]
Email: [e-mail]
Charles E. Merrill - 87861
MERRILL, NOMURA & MOLINEUX LLP
65 Oak Court
Danville, CA 94526
Telephone: [phone]
Email: [e-mail]
Attorneys for Plaintiff
Sustainable Ranching Partners, Inc.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SUSTAINABLE RANCHING PARTNERS, )
INC.,
)
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Plaintiff,
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vs.
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BERING PACIFIC RANCHES LTD., et al., )
)
Defendants.
)
)

Case No.: 17-cv-02323-JST
STIPULATION AND PROPOSED ORDER
RE: CONTINUING INITIAL CASE
MANAGEMENT CONFERENCE AND
RELATED DATES
SECOND REQUEST

Plaintiff Sustainable Ranching Partners, Inc. ("Sustainable") and Defendants Patrick Harvie

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and Bering Pacific Ranches Limited (collectively "BPR"), by and through counsel, stipulate and

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agree as follows:

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WHEREAS, at the request of the parties and given the pendency of a Motion to Dismiss and

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Alternative Motion to Transfer Venue filed by BPR as to Plaintiff's Complaint, this Court

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previously entered an Order on July 10, 2017 continuing the initial Case Management Conference

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to September 27, 2017 [Dkt. Nos., 22, 23];

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WHEREAS, since issuing the Order, BPR filed a further Motion to Dismiss and Alternative

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Motion to Transfer Venue as to Plaintiff's First Amended Complaint [Dkt. No. 24], originally

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setting the hearing on that motion for August 24, 2017;

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WHEREAS, the Court reset the hearing on Defendant's pending Motion to Dismiss and
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STIPULATION

Case No.: 17-cv-02323-JST

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Alternative Motion to Transfer Venue to September 21, 2017 [Dkt. No. 25];
WHEREFORE, given the proximity of the hearing date on the renewed Motion to Dismiss

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and Alternative Motion to Transfer Venue to the Case Management Conference and in order to save

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resources, the parties are agreeable to and jointly request that this Court continue the September 27,

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2017 Case Management Conference for 30 or more days so as to permit for this Court to rule upon

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BPR's pending Motion to Dismiss and Alternative Motion to Transfer Venue.
IT IS SO AGREED.

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Dated: August 30, 2017

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MORALES FIERRO & REEVES

TROUTMAN SANDERS LLP

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/s/ William C. Reeves
William C. Reeves
Attorneys for Plaintiff

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Pursuant to Local Rule 5-1, the undersigned attests that counsel for Defendant has consented

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By:

By:

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/s/ Dean A. Morehous
Dean A. Morehous
Attorneys for Defendants

in the filing of this stipulation.

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By:

/s/ William C. Reeves
William C. Reeves
ORDER

The Court, having considered the stipulation of the parties and good cause appearing, orders
as follows:

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1.

The Case Management Conference set for September 27, 2017 is continued to

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November 1

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2.

, 2017 at

2:00

--am./pm.
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Pursuant to FRCP 26, the parties must file a Joint Case Management Statement and

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complete their Initial Disclosures by no later than seven (7) days for the continued Case

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Management Conference.

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IT IS SO ORDERED.
Dated: August 31, 2017

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UNITED STATES DISTRICT JUDGE

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STIPULATION

Case No.: 17-cv-02323-JST