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

Filing 41

STIPULATION AND ORDER re 40 STIPULATION WITH PROPOSED ORDER re 34 Clerk's Notice, 38 MOTION to Dismiss Plaintiff's Second Amended Complaint filed by Sustainable Ranching Partners, Inc. Case Management Statement due by 2/13/2018. Initial Case Management Conference set for 2/22/2018 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on December 27, 2017. (wsn, COURT STAFF) (Filed on 12/27/2017)

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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.,
)
)
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: EXTENDING DEADLINE TO
RESPOND TO DEFENDANTS' MOTION
TO DISMISS AND RESCHEDULING THE
CASE MANAGEMENT CONFERENCE

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

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

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agree as follows:

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WHEREAS, on December 22, 2017, Defendants filed a Motion to Dismiss Plaintiff's
Second Amended Complaint [Dkt. No. 38];
WHEREAS, this Court re-scheduled the hearing date on Defendants' Motion to 2:00 p.m. on
February 22, 2018 [Dkt. No. 39];

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WHEREAS, given the holidays, Plaintiff and Defendants (collectively "Parties") are

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amenable to extending the date for Plaintiff to respond to Defendants' Motion to January 16, 2018;

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WHEREAS, a Case Management Conference is currently scheduled for January 24, 2018
[Dkt. No. 34];
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STIPULATION

Case No.: 17-cv-02323-JST

WHEREAS, counsel for the Plaintiff has a conflict on January 24, 2018 due to a multi-party

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mediation;
WHEREAS, counsel for Defendant is amenable to rescheduling the Case Management

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Conference for February 22, 2018, the same day as the hearing on their Motion to Dismiss;
WHEREFORE, based on the foregoing, and subject to this Court's approval, the Parties

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stipulate and agree as follows:

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1.

The deadline for Plaintiff to oppose the Motion to Dismiss shall be January 16, 2018;

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2.

The Case Management Conference shall be set 2:00 p.m. on February 22, 2018.

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IT IS SO AGREED.

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Dated: December 26, 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:

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

in the filing of this stipulation.

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By:

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/s/ William C. Reeves
William C. Reeves

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

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1.

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2.

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IT IS SO ORDERED.

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The deadline for Plaintiff to oppose the Motion to Dismiss shall be January 16, 2018;
Replies are due by January 23, 2018.
The Case Management Conference shall be held on February 22, 2018 at 2:00 p.m.

Dated: December 27, 2017

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UNITED STATES DISTRICT JUDGE
HON. JON S. TIGAR

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STIPULATION

Case No.: 17-cv-02323-JST