1 

________________________________________________________________________________ CHANEL, ET AL. V. BOSINI, ET AL.: THIRD STIPULATION FOR ADDITIONAL 

TIME TO FILE STIPULATION FINALIZING SETTLEMENT 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

J. Andrew Coombs (SBN 123881) 

Nicole L. Drey (SBN 250235) 

J. Andrew Coombs, A Prof. Corp. 

517 East Wilson Avenue, Suite 202 

Glendale, California 91206 

Telephone: (818) 500-3200 

Facsimile: (818) 500-3201 

andy@coombspc.com 

nicole@coombspc.com 

Stephen M. Gaffigan (Admitted Pro Hac Vice) 

Stephen M. Gaffigan, P.A. 

401 East Las Olas Blvd., Suite 130-453 

Ft. Lauderdale, Florida 33301 

Telephone: (954) 767-4819 

Facsimile: (954) 767-4821 

stephen@smgpa.net 

Attorneys for Plaintiffs 

Chanel, Inc. and Louis Vuitton Malletier, S.A. 

THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA 

CHANEL, INC., a New York corporation 

and LOUIS VUITTON MALLETIER, 

S.A., a foreign business entity, 

Plaintiffs, 

v. 

TONY BOSINI and DOES 1-10, 

individually and jointly, d/b/a 

REPLICAMASTER.COM, 

SHOPREPLICA.COM, 

BUYHIGHREPLICA.COM, 

EREPLICABAGS.COM, 

EXACTWATCHES.NET, 

REPLICAHOURS.COM, 

SWISSREPLICA.US, 

THEWATCHESPRICEINDEX.INFO, 

YOURREPLICAWATCH.COM, and 

REPLICAHAUSE.COM 

Defendants. 

) 

) 

) 

) 

) 

) 

) 

) 

)

)

) 

) 

) 

) 

) 

) 

) 

) 

Case No. C-09-1972 MHP 

THIRD STIPULATION FOR 

ADDITIONAL TIME TO FILE 

STIPULATION FINALIZING 

SETTLEMENT 

Plaintiffs, CHANEL, INC., a New York corporation ("Chanel") and LOUIS VUITTON 

MALLETIER, S.A. (“Louis Vuitton”), and the Defendant Tony Bosini (“Bosini”), by and through 

Case 3:09-cv-01972-BZ Document 54 Filed 03/16/10 Page 1 of 3
2

CHANEL, ET AL. V. BOSINI, ET AL.: THIRD STIPULATION FOR ADDITIONAL 

TIME TO FILE STIPULATION FINALIZING SETTLEMENT 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

their undersigned counsel, hereby stipulate to an additional four days, up to and including March 19, 

2010, in which to file the Stipulation finalizing settlement in this matter, and state as follows: 

1. On February 4, 2010, the parties submitted their Joint Notice of Settlement advising 

they anticipated finalizing the settlement in this matter within the next 20 days, i.e. February 24, 

2010. 

2. On February 24, 2010, the parties submitted a Stipulation for Additional Time to File 

Stipulation Finalizing Settlement advising the Court that the parties had exchanged settlement papers 

in this matter, and anticipated submitting the Stipulation finalizing the settlement of this matter to the 

Court on or before March 8, 2010. On March 1, 2010, this Court entered an Order granting the 

parties’ requested enlargement. 

3. On March 8, 2010, the parties submitted a second Stipulation for Additional Time to 

File Stipulation Finalizing Settlement advising the Court that due to travel schedules Defendant’s 

counsel was unable to finalize the terms of the settlement with the Defendant, and that the parties 

anticipated submitting the Stipulation finalizing the settlement of this matter to the Court on or 

before March 15, 2010. On March 9, 2010, this Court entered an Order granting the parties’ 

requested enlargement. 

4. As of this date, final settlement papers have been provided to each respective party, 

and the parties are in the process of executing the settlement papers in this matter. The parties 

anticipate exchanging fully signed settlement papers in this matter, and submitting the necessary 

Case 3:09-cv-01972-BZ Document 54 Filed 03/16/10 Page 2 of 3
3

CHANEL, ET AL. V. BOSINI, ET AL.: THIRD STIPULATION FOR ADDITIONAL 

TIME TO FILE STIPULATION FINALIZING SETTLEMENT 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Stipulation finalizing this matter with the Court on or before Friday, March 19, 2010. 

SO STIPULATED: 

Plaintiffs: Chanel, Inc. and Louis Vuitton Malletier, S.A. 

 

By their Attorney: STEPHEN M. GAFFIGAN, P.A.,

 A PROFESSIONAL ASSOCIATION

 By: s:/Stephen M. Gaffigan

Attorneys for Plaintiffs 

Chanel, Inc. and Louis Vuitton Malletier, S.A. 

Defendants: Tony Bosini d/b/a Replicamaster.com, Shopreplica.com, Buyhighreplica.com, 

Ereplicabags.com, Exactwatches.net, Replicahours.com, Swissreplica.US, 

Thewatchespriceindex.info, Yourreplicawatch.com and Replicahause.com 

By his Attorney: LAW OFFICE OF AYAL ABRAMS 

 By:___/s Ayal Abrams______________________ 

 Ayal Abrams 

 600 Page Street, #101 

 San Francisco, California 94117 

 Telephone: (415) 994-2437 

 Facsimile: (415) 358-4951 

 Attorneys for Defendant 

 Tony Bosini 

 SO ORDERED this _______ day of _____________, 2010. 

___________________________________ 

 UNITED STATES MAGISTRATE JUDGE 

Copies furnished to: 

All parties of record 

16th March BERNARD ZIMMERMAN

Case 3:09-cv-01972-BZ Document 54 Filed 03/16/10 Page 3 of 3