Park Miller, LLC et al v. Durham Group, Ltd. et al

Filing 16

STIPULATION AND ORDER to extend time to respond to 13 MOTION to Dismiss.Response due by 10/16/2019. Reply due by 10/30/2019. Motion Hearing reset for 11/13/2019 02:00 PM in San Francisco, Courtroom 02, 17th Floor before Judge William H. Orrick. Signed by Judge William H. Orrick on 10/4/2019. (jmdS, COURT STAFF) (Filed on 10/4/2019)

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RICHARD T. BOWLES (#46234)
ALEXANDREA M. TOMP (#324022)
Bowles & Verna LLP
2121 N. California Blvd., Suite 875
Walnut Creek, California 94596
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Plaintiffs
Park Miller, LLC, Henry S. Lawson,
Marcia Lawson, Lawson Land, Inc.,
Edward Miner, James Combs, Dorothy
Combs, Gregory Combs and Suzanne
Combs

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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PARK MILLER, LLC, a Delaware limited liability
company, HENRY S. LAWSON, an individual and
co-trustee of the LAWSON CHARITABLE
REMAINDER UNITRUST and co-trustee of the
LAWSON FAMILY TRUST, MARCIA
LAWSON, an individual and co-trustee of the
LAWSON CHARITABLE REMAINDER
UNITRUST and co-trustee of the LAWSON
FAMILY TRUST, LAWSON LAND, INC., a
California corporation, EDWARD MINER, an
individual and trustee of the MINER 2003 LIVING
TRUST, EDWARD MINER SEPARATE
PROPERTY, JAMES COMBS an individual and
co-trustee of the JAMES AND DOROTHY
COMBS FAMILY LIVING TRUST, DOROTHY
COMBS, an individual and co-trustee of the
JAMES AND DOROTHY COMBS FAMILY
LIVING TRUST, GREGORY M. COMBS, an
individual and co-trustee of the GREGORY M.
AND SUZANNE B. COMBS FAMILY LIVING
TRUST, and SUZANNE B. COMBS, an individual
and co-trustee of the GREGORY M. AND
SUZANNE B. COMBS FAMILY LIVING
TRUST,

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Case No. 19-cv-04185-WHO
STIPULATED REQUEST TO EXTEND
TIME TO RESPOND TO DEFENDANTS’
MOTION TO DISMISS; ORDER

Plaintiffs,

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v.

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DURHAM GROUP, LTD., a New York
Corporation, DURHAM COMMERCIAL

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STIPULATED REQUEST TO EXTEND TIME TO RESPOND TO DEFENDANTS’ MOTION TO
DISMISS

Bowles & Verna LLP
2121 N. California
Suite 875
Walnut Creek 94596

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CAPITAL CORP., a New York Corporation,
MAASAI HOLDINGS LLC, a New York limited
liability company, FIRST AUSTIN FUNDING
CORP., a New York corporation, CRAIG
MCGRAIN, an individual, and DOES 1-50,
inclusive

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Defendants.
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Pursuant to Civil Local Rule 6-1 and 6-2 of the Northern District of California, the parties

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through undersigned counsel stipulate and respectfully request that the Court extend the deadline for

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Plaintiffs to respond to Defendants’ Motion to Dismiss for Lack of Personal Jurisdiction and for

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Failure to State a Claim filed on September 25, 2019 (“Motion to Dismiss”) due to the complex nature

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of the claims and the number of parties involved.

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The parties hereby stipulate, subject to approval of the Court, as follows:

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1.

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October 16, 2019.

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2.

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Plaintiffs’ Response to Defendants’ Motion to Dismiss will be filed on our before

Defendants’ Reply to Plaintiffs’ Response to Defendants’ Motion to Dismiss will be

filed on or before October 30, 2019.
This is the first extension in this case regarding the present motion. A previous stipulation was
entered to extend Defendants’ time to respond to the Complaint.
The amendment of these dates will not affect any other deadlines or hearing dates in this action
The Motion Hearing for Defendants’ Motion to Dismiss is currently set for November 13, 2019.
IT IS SO STIPULATED AND AGREED.

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STIPULATED REQUEST TO EXTEND TIME TO RESPOND TO DEFENDANTS’ MOTION TO
DISMISS

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Dated: October 4, 2019

BOWLES & VERNA LLP

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By: /s/ Alexandrea M. Tomp
RICHARD T. BOWLES
ALEXANDREA M. TOMP
Attorneys for Plaintiffs
Park Miller, LLC, Henry S. Lawson,
Marcia Lawson, Lawson Land, Inc.,
Edward Miner, James Combs, Dorothy
Combs, Gregory Combs and Suzanne
Combs

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Dated: October 4, 2019

CARLSON & MESSER LLP

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By: /s/June D. Coleman
JUNE D. COLEMAN
Attorneys for Defendants
Durham Group, Ltd., Durham Commercial
Capital Corp., Maasai Holdings LLC, First
Austin Funding Corp., and Craig McGrain

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FILER’S ATTESTATION
Pursuant to Civil Local Rule 5-1(i)(3), regarding signatures, I, Alexandrea M. Tomp, attest that
concurrence in the filing of this document has been obtained.

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By: /s/ Alexandrea M. Tomp

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ORDER

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IT IS ORDERED that the foregoing Agreement is approved.
Dated: October 4, 2019
By: ____________________________
HONORABLE WILLIAM H. ORRICK
United States District Judge

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STIPULATED REQUEST TO EXTEND TIME TO RESPOND TO DEFENDANTS’ MOTION TO
DISMISS