Rainbow Business Solutions et al v. Merchant Services, Inc et al

Filing 437

STIPULATION AND MODIFIED ORDER re #436 STIPULATION re #428 MOTION to Compel LEASING DEFENDANTS PRODUCTION OF MATERIALS FROM OTHER LAWSUITS, #429 MOTION for Sanctions FOR LEASING DEFENDANTS' FAILURE TO COMPLY WITH JUNE ORDER AND STIPULATION

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ROD O. DIVELBISS (SBN 102345)
[e-mail]
COLLETTE ERICKSON FARMER & O’NEILL LLP
235 PINE STREET, SUITE 1300
SAN FRANCISCO, CA 94104
TELEPHONE: [phone]
FACSIMILE: [phone]
SCOTT E. SILBERFEIN (Pro Hac Vice)
JENNIFER NIGRO (Pro Hac Vice)
MOSES & SINGER LLP
The Chrysler Building
405 Lexington Avenue
New York, New York 10174-1299
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendants Northern Leasing Systems, Inc., MBF
Leasing, LLC, Northern Funding, LLC, SKS Associates, LLC, Jay
Cohen, Sara Krieger, Leonard Mezei and Sam Buono

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION

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JUST FILM, INC.; ET AL.,

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Plaintiffs,
v.
MERCHANT SERVICES, INC.; ET AL.,

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Defendants.

CASE NO. CV 10-01993 CW
JOINT STIPULATION PURSUANT TO
LOCAL CIVIL RULE 6-2(b) TO
EXTEND TIME TO RESPOND TO
PLAINTIFFS’ MOTION TO COMPEL AND
PLAINTIFFS’ MOTION TO SANCTION
AND ORDER

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Case No. C 10-1993 CW
JOINT STIPULATION PURSUANT TO LOCAL CIVIL RULE 6-2 TO EXTEND TIME TO RESPOND TO
PLAINTIFFS’ MOTION TO COMPEL AND PLAINTIFFS’ MOTION TO SANCTION

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WHEREAS, on December 11, 2012, Plaintiffs filed a motion to compel Leasing

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Defendants (Northern Leasing Systems, Inc., MBF Leasing, LLC, Northern Funding, LLC, SKS

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Associates, LLC, Jay Cohen, Sara Krieger, Leonard Mezei and Sam Buono) to produce documents

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from other lawsuits, and a motion to sanction Leasing Defendants for failure to comply with

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discovery (dkt. #s 428 and 429, respectively) (“Plaintiffs’ Motions”);

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WHEREAS, under the Local Rules, Leasing Defendants’ response(s) to Plaintiffs Motions

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would be due the week of the Christmas holiday when the parties and counsel will be unavailable;

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WHEREAS, Plaintiffs’ replies are due to be filed and served on January 2, 2013;

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WHEREAS, the hearing on Plaintiffs’ Motions is set for January 15, 2013;

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WHEREAS, no prior extensions with respect to Plaintiffs’ Motions have been requested;

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NOW, THEREFORE, IT IS STIPULATED, by and between the undersigned parties

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through their respective counsel of record, pursuant to Local Civil Rules 6-1(b) and 2(a), that the

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Court extend Leasing Defendants’ time to respond to Plaintiffs’ Motions from December 26, 2012

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to January 3, 2013. Defendants shall have an extension to January 3, 2013 to file and serve their

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responses to Plaintiffs’ Motions; Plaintiff shall have an extension to January 8, 2013 to file their

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replies; and the hearing on Plaintiffs’ Motions shall be January 15, 2012 at 9:00 a.m. before Hon.

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Magistrate Judge Elizabeth Laporte.

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DATED: December 19, 2012

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January 29, 2013, at 4:00 p.m.

Respectfully submitted,
MOSES & SINGER LLP
By

/s/ Jennifer Nigro
Jennifer Nigro

Attorneys for Defendants Northern Leasing
Systems, Inc., MBF Leasing, LLC, Northern
Funding, LLC, SKS Associates, LLC,
Jay Cohen, Sara Krieger, Leonard Mezei and
Sam Buono
Scott E. Silberfein (pro hac vice)
Jennifer Nigro (pro hac vice)
Moses & Singer LLP
Case No. C 10-1993 CW
JOINT STIPULATION PURSUANT TO LOCAL CIVIL RULE 6-2 TO EXTEND TIME TO RESPOND TO
PLAINTIFFS’ MOTION TO COMPEL AND PLAINTIFFS’ MOTION TO SANCTION

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Rod O. Divelbiss
Collette Erickson Farmer & O’Neill LLP

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GUTRIDE SAFIER LLP

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By:

/s/ Kristen Simplicio
Kristen Simplicio, Esq.

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Attorneys for Plaintiffs

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R NIA

NO

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UNITED STATES MAGISTRATEeJUDGE
rt
D. Lapo
lizabeth
Judge E

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FO

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DERED
SO OR ED
________________________________________
IT IS
DIFI
THE HONORABLEO
AS M ELIZABETH D. LAPORTE

LI

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DATED: December 27, 2012

S DISTRICT
TE
C
TA

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A

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IT IS SO ORDERED.

RT
U
O

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Pursuant to Local Civil Rule 6-2(a), and GOOD CAUSE APPEARING THEREFOR,

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UNIT
ED

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N

D IS T IC T
R

OF

C

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Case No. 10-0-1993 CW

JOINT STIPULATION PURSUANT TO LOCAL CIVIL RULE 6-2 TO EXTEND TIME TO RESPOND TO
PLAINTIFFS’ MOTION TO COMPEL AND PLAINTIFFS’ MOTION TO SANCTION