LESA, LLC v. Family Trust of Kimberley and Alfred Mandel et al

Filing 11

ORDER (AS MODIFIED) 9 GRANTING STIPULATION WITH PROPOSED ORDER. Motion Hearing set for 2/18/2016 at 11:00 AM before Magistrate Judge Kandis A. Westmore. Signed by Judge Kandis A. Westmore on 01/11/2016. (kawlc2S, COURT STAFF) (Filed on 1/11/2016)

1 Jack Russo (Cal. Bar No. 96068)
Christopher Sargent (Cal. Bar No. 246285)
2 COMPUTERLAW GROUP LLP
401 Florence Street
3 Palo Alto, CA 94301
[phone]
4 [phone] fax
[e-mail]
5 [e-mail]
6
Attorneys for Plaintiff
7 LESA, LLC
8

U NITED S TATES D ISTRICT C OURT

9

N ORTHERN D ISTRICT OF C ALIFORNIA

10

O AKLAND D IVISION

Computerlaw Group LLP
www.computerlaw.comsm

11
12

LESA, LLC, a Delaware Limited Liability
Company;

13
Plaintiff,
14

Case No. 4:15-cv-05574-KAW
STIPULATION AND [PROPOSED] ORDER
ENLARGING TIME RE: DEFENDANTS’
MOTION TO DISMISS.

v.
15
16
17
18

Family Trust of Kimberly and Alfred
Mandel, a California Trust;
2000 Jackson Family Trust, a California
Trust;
Richard “Dick” Taylor, an individual;
James Fisher, an individual; and
Christine Williams, an individual;

19
Defendants.
20
21
22
23
24
25
26
27
28
Stip. and [Prop] Order Enlarging Time

Case No.: 4:15-cv-05574-KAW

1

S TIPULATION E NLARGING T IME RE: D EFENDANTS ’ M OTION TO D ISMISS

2

This Stipulation is entered into by Plaintiff LESA, LLC and Defendants Family Trust of

3 Kimberley and Alfred Mandel, 2000 Jackson Family Trust, Richard “Dick” Taylor, James Fisher,
4 and Christine Williams (collectively, “Defendants”) by their respective counsel.
5

R ECITALS

6

A.

Plaintiff LESA, LLC filed its Complaint on December 4, 2015 (Dkt. 1)

7

B.

Defendants filed their Motion to Dismiss the Complaint (the “Motion”) on

8 December 23, 2015 (Dkt. 7), set for hearing on February 4, 2016. Under Civil Local Rule 7-3,
9 Plaintiff’s deadline to file its Opposition to the Motion is January 6, 2016.
10

C.

Counsel for Plaintiff was unavailable due to personal reasons for an extended

Computerlaw Group LLP
www.computerlaw.comsm

11 period of time between December 24, 2015 and January 4, 2016.
S TIPULATION

12
13

To accommodate Counsel’s personal situation, the Parties hereby stipulate to modify the

14 briefing schedule for the Motion as follows:
15

Plaintiff’s Opposition Due:

Wednesday, January 20, 2016

16

Defendants’ Reply Due:

Wednesday, January 27, 2016

17

Hearing:

Thursday, February 4, 2016

18

18 IT IS SO STIPULATED.
COMPUTERLAW GROUP LLP

19
20

Dated: January 4, 2016

By:

21

/s/ Jack Russo
Jack Russo
Christopher Sargent

22

Attorneys for Plaintiff
LESA, LLC.

23

ROYSE LAW FIRM, PC

24 Dated: January 4, 2016

By:

25
26

/s/ Thomas E. Moore III
Thomas E. Moore III
Lisa Chapman
Attorneys for Defendants
FAMILY TRUST OF KIMBERLEY AND ALFRED
MANDEL, 2000 JACKSON FAMILY TRUST,
RICHARD TAYLOR, JAMES FISHER, AND
CHRISTINE WILLIAMS.

27
28
Stip. and [Prop] Order Enlarging Time

1

Case No.: 4:15-cv-05574-KAW

1

ATTESTATION OF E-FILED SIGNATURE

2

I, Jack Russo, am the ECF user whose ID and password are being used to file this

3 declaration. In compliance with Civil L.R. 5-1(i)(3), I hereby attest that Thomas E. Moore III has
4 concurred in this filing’s content and has authorized this filing.
5
6 Dated: January 4, 2016

By:

7

/s/ Jack Russo
Jack Russo

8
9
10

PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated: 01/11

, 2016
Hon. Kandis A. Westmore
United States Magistrate Judge

Computerlaw Group LLP
www.computerlaw.comsm

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Stip. and [Prop] Order Enlarging Time

2

Case No.: 4:15-cv-05574-KAW