Joe Hand Promotions, Inc. v. McInnis et al

Filing 41

STIPULATION AND ORDER Extending ADR Deadline. Signed by Judge Koh on 3/4/2011.(lhklc4, COURT STAFF) (Filed on 3/4/2011) (Additional attachment(s) added on 3/4/2011: # 1 Certificate of Mailing) (lhklc4, COURT STAFF).

Joe Hand Promotions, Inc. v. McInnis et al

Doc. 41

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Thomas P. Riley, SBN 194706 LAW OFFICES OF THOMAS P. RILEY, P.C. First Library Square 1114 Fremont Avenue South Pasadena, CA 91030-3227 Tel: [phone] Fax: [phone] [e-mail] Attorneys for Plaintiff Joe Hand Promotions, Inc. Thomas Rich McInnis
101 Esplanade Aptos, CA 95003

Defendant, Pro Se UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION JOE HAND PROMOTIONS, INC., Plaintiff, v. THOMAS RICH McINNIS, et al. Case No. 5:10-cv-01614-LHK STIPULATION OF PLAINTIFF JOE HAND PROMOTIONS, INC. AND DEFENDANT THOMAS RICH McINNIS STIPULATION TO EXTEND THE ADR DEADLINE; AND ORDER (Proposed)

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Defendant. TO THE HONORABLE LUCY H. KOH, THE PARTIES, AND THEIR ATTORNEY/S OF RECORD: By and through their counsel, Plaintiff Joe Hand Promotions, Inc., and Defendant Thomas Rich

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McInnis, hereby agree, stipulate, and respectfully request that this Honorable Court extend the ADR
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deadline in the instant action from February 28, 2011 to April 7, 2011 pursuant to ADR Local Rule 651.
Plaintiff's counsel and defendant Thomas Rich McInnis sincerely apologize that this Stipulation is filed late and not fourteen (14) days or more beyond the presently scheduled ADR deadline of February 28, 2011. Due to difficulties in Plaintiff's counsel reaching defendant McInnis and Mr. McInnis reaching Plaintiff's counsel throughout the month of February 2011, their participation in the pre mediation teleconference with Court appointed mediator Vicki Veenker was delayed, which in turn delayed preparation and filing of this Stipulation.
STIPULATION OF PLAINTIFF JOE HAND PROMOTIONS, INC. AND DEFENDANT THOMAS RICH MCINNIS STIPULATION TO EXTEND THE ADR DEADLINE; AND ORDER (Proposed) CASE NO. 5:10-cv-01614-LHK

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Dockets.Justia.com

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1.

This request is necessary because, due to scheduling conflicts of defendant Thomas

Rich McInnis and Plaintiff's counsel Thomas P. Riley, the Parties were unable to concur with Court appointed mediator Vicki Veenker until Wednesday, February 23, 2011. In this telephonic conference however, defendant Thomas Rich McInnis, Plaintiff's counsel, and mediator Veenker were able to conduct a meaningful discussions towards settlement and the procedures to be followed at the Court ordered mediation. In the teleconference the participants were further able to clear the date of Thursday, April 7, 2011 as the first mutually convenient date to conduct the mediation. 2. Court appointed mediator Vicki Veenker interposes no objection to the extension of

the present ADR deadline from February 28, 2011 to and through April 7, 2011. WHEREFORE, IT IS HEREBY STIPULATED BY AND RESPECTFULLY REQUESTED BY THE PARTIES that the Court continue the deadline to conduct the ADR from February 28, 2011 to and through Thursday, April 7, 2011.

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Respectfully submitted,
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Dated: February 25, 2011

/s/ Thomas P. Riley LAW OFFICES OF THOMAS P. RILEY, P.C. By: Thomas P. Riley Attorneys for Plaintiff Joe Hand Promotions, Inc.

Dated: February 25, 2011

/s/ Thomas Rich McInnis Thomas Rich McInnis Defendant

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STIPULATION OF PLAINTIFF JOE HAND PROMOTIONS, INC. AND DEFENDANT THOMAS RICH MCINNIS STIPULATION TO EXTEND THE ADR DEADLINE; AND ORDER (Proposed) CASE NO. 5:10-cv-01614-LHK

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ORDER (Proposed) IT IS HEREBY ORDERED that the ADR deadline in civil action 5:10-cv-01614-LHK styled Joe Hand Promotions, Inc. v. Thomas Rich McInnis, et al. is hereby continued from February 28, 2011 to and through Thursday, April 7, 2011.

IT IS SO ORDERED:

Dated: THE HONORABLE LUCY H. KOH United States District Court Northern District of California ///

March 4, 2011

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STIPULATION OF PLAINTIFF JOE HAND PROMOTIONS, INC. AND DEFENDANT THOMAS RICH MCINNIS STIPULATION TO EXTEND THE ADR DEADLINE; AND ORDER (Proposed) CASE NO. 5:10-cv-01614-LHK