Trader Joe's Company v. Hallatt et al

Filing 70

ORDER granting Plaintiff's 69 Motion for Leave to File Second Amended Complaint. Signed by Judge Barbara J. Rothstein. (PM)

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The Honorable Barbara J. Rothstein

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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TRADER JOE'S COMPANY, a
California Corporation,
Plaintiff,

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v.
MICHAEL NORMAN HALLATT, an
individual, d/b/a PIRATE JOE'S a/k/a
TRANSILVANIA TRADING; and
DOES 1-10,

No. 2:13-cv-00768-BJR
STIPULATED MOTION AND
ORDER GRANTING LEAVE FOR
TRADER JOE'S TO FILE SECOND
AMENDED COMPLAINT
NOTE ON MOTION CALENDAR:
March 27, 2017

Defendants.

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STIPULATED MOTION

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Pursuant to Rule 15(a)(2) of the Federal Rules of Civil Procedure and LCR 15,

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Plaintiff Trader Joe’s Company (“Trader Joe’s”) and Defendant Michael Hallatt (“Mr.

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Hallatt”) jointly stipulate as follows:

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WHEREAS, on December 20, 2016, the Court issued an order setting March 28,
2017 as the deadline for amended pleadings (ECF No. 58);
WHEREAS, the parties have agreed that, subject to the Court’s approval, Trader

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Joe’s may file its Proposed Second Amended Complaint, a redlined copy of which is

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attached as Exhibit A to this stipulation;
STIPULATED MOTION AND ORDER GRANTING
LEAVE FOR TRADER JOE'S TO FILE SECOND
AMENDED COMPLAINT
NO. 2:13-cv-00768 – Page 1

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NOW, THEREFORE, with the Court’s permission and approval, the parties hereby

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stipulate and respectfully request that the Court grant Trader Joe’s leave to file its Second

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Amended Complaint, as reflected in Exhibit A to this stipulation.

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Dated: March 27, 2017.
YARMUTH WILSDON PLLC

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By /s/ Jeremy E. Roller
Scott T. Wilsdon, WSBA No. 20608
Jeremy E. Roller, WSBA No. 32021
1420 Fifth Avenue, Suite 1400
Seattle, WA 98101
Telephone: [phone]
Facsimile: 206.516.3888
[e-mail]
[e-mail]

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O’MELVENY & MYERS LLP

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Brian M. Berliner, (pro hac vice)
Jordan Raphael, (pro hac vice)
Tim Byron (pro hac vice)
400 South Hope Street
Los Angeles, CA 90071-2899
Telephone: [phone]
Facsimile: 213.430.6407
[e-mail]
[e-mail]
[e-mail]

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Attorneys for Plaintiff Trader Joe’s Company

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Dated: March 27, 2017.

DORSEY & WHITNEY LLP

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/s/ Nathan Alexander
Nathan Alexander, WSBA No. 37040
Michael Keyes, WSBA No. 29215
Andrea Yang, WSBA No. 50613
701 Fifth Avenue, Suite 6100
Seattle, WA 98104-7043
Telephone: [phone]
Facsimile: 206.903.8820
[e-mail]
[e-mail]
[e-mail]

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Attorneys for Defendants

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STIPULATED MOTION AND ORDER GRANTING
LEAVE FOR TRADER JOE'S TO FILE SECOND
AMENDED COMPLAINT
NO. 2:13-cv-00768 – Page 2

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ORDER

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IT IS SO ORDERED.

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Dated: April 3, 2017

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A

Barbara Jacobs Rothstein
U.S. District Court Judge

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STIPULATED MOTION AND ORDER GRANTING
LEAVE FOR TRADER JOE'S TO FILE SECOND
AMENDED COMPLAINT
NO. 2:13-cv-00768 – Page 3

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CERTIFICATE OF SERVICE
I hereby certify that on this date I electronically filed the foregoing with the Clerk of

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the Court using the CM/ECF system, which will send notification of such filing to the

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following counsel of record:

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Nathan T. Alexander ([e-mail])
Michael Keyes ([e-mail])
Andrea Yang ([e-mail])
DORSEY & WHITNEY LLP

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Attorneys for Defendant Michael Norman Hallatt

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Dated: March 27, 2017 at Seattle, Washington.
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s/Jeremy E. Roller
Jeremy E. Roller

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STIPULATED MOTION AND ORDER GRANTING
LEAVE FOR TRADER JOE'S TO FILE SECOND
AMENDED COMPLAINT
NO. 2:13-cv-00768 – Page 4