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STIPULATION

Shawn M. Krogh SBN 227116

Frank M. Radoslovich SBN 161457

RADOSLOVICH LAW CORPORATION

601 University Avenue, Suite 250

Sacramento, CA 95825

Telephone: (916) 565-8161

Facsimile: (916) 565-8170

Attorney for Defendant

ROBERT B. FRAIDENBURGH

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA

IMPRIMIS INTERNATIONAL, INC.

 Plaintiff,

vs.

ROBERT B. FRAIDENBURGH,

 Defendant. 

CASE NO. CIV.S-04-1297 FCD DAD

STIPULATION

Trial Date: November 15, 2005

IT IS HEREBY AGREED to and STIPULATED by and between the attorneys for Plaintiff

IMPRIMIS INTERNATIONAL, INC. and Defendant ROBERT B. FRAIDENBURGH that Section

IV of the Status (Pretrial Scheduling) Order be modified to provide that all discovery be completed

by June 30, 2005.

The following demonstrates “good cause” as required for modification of the Status Order:

1. On April 18, 2005, Defendant noticed the depositions of Plaintiff’s person most

knowledgeable and Ben Hord (an employee of Plaintiff). The deposition notices provide that the

depositions will take place on May 9, 2005.

2. Plaintiff’s counsel is participating a trial in Virginia which will be taking place from

May 2, 2005 through May 9, 2005.

3. Ben Hord, who will be designated as Plaintiff’s person most knowledgeable will be

in Thailand until May 24, 2005.

/ / / 

Case 2:04-cv-01297-FCD-DAD Document 19 Filed 05/12/05 Page 1 of 4
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STIPULATION

4. Plaintiff and Defendant are continuing to informally resolve outstanding discovery

disputes relating to the Defendant’s First Set of Special Interrogatories.

5. Plaintiff and Defendant have agreed that the deposition of Plaintiff’s person most

knowledgeable and Ben Hord will take place on June 7, 2005.

In sum, the parties hereby Stipulate and Agree that based upon the foregoing, good cause

exists to modify Section IV of the Status Order to provide that all discovery be completed by June

30, 2005.

WHEREFORE, Plaintiff and Defendant hereby stipulate and request that the May 12, 2005,

close of discovery date by vacated and that the Status Order be modified to provide that all discovery

be completed by June 30, 2005.

IT IS SO STIPULATED.

Dated: ____4/21/2005__________. ________/s/___________________

Shawn M. Krogh

Attorney for Defendant ROBERT B.

FRAIDENBURGH

Dated:____4/21/2005__________. ________/s/___________________

Stephen A. Bamberger

Attorney for Plaintiff IMPRIMIS

INTERNATIONAL, INC.

Case 2:04-cv-01297-FCD-DAD Document 19 Filed 05/12/05 Page 2 of 4
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STIPULATION

PROPOSED ORDER

WHEREFORE, based upon a finding of good cause, the Court hereby vacates that May 12,

2005, close of discovery date. 

IT IS FURTHER ORDERED that the Status Order be modified to provide that all discovery

be completed by June 30, 2005.

IT IS FURTHER ORDERED in light of the extension of the discovery completion date the

court moves the following deadlines: all disposition motions shall be heard no later than 

September 9, 2005. The final pretrial conference is RESET to Friday, December 9, 2005 at 

2:30 p.m. The Joint Pretrial Statement shall be filed on or before December 2, 2005. The jury trial

is RESET to Tuesday, February 28, 2006 at 9:00 a.m.

DATED: May 12, 2005

/s/ Frank C. Damrell Jr. 

FRANK C. DAMRELL JR.

United States District Judge

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STIPULATION

COURT: United States District Court, Eastern District of California

CASE NO.: CIV. S-04-1297 FCD DAD

CASE NAME: Imprimis International, Inc. v. Robert B. Fraidenburgh

 

PROOF OF SERVICE

I am a citizen of the United States, employed in the County of Sacramento. My business

address is 601 University Ave, Suite 250, Sacramento, California 95825. I am over the age of 18

years and not a party to the above-entitled action.

I am familiar with Radoslovich LawCorporation’s practice whereby each document is placed

in an envelope, the envelope is sealed, the appropriate postage is placed thereon and the sealed

envelope is placed in the office mail receptacle. Each day's mail is collected and deposited in a U.S.

mailbox at or before the close of each day's business.

On the date indicated below, I served the within:

 

 

 STIPULATION 

 

 BY MAIL---

Placed in the United States Mail at Sacramento, California, a true copy in a sealed envelope

with first class postage affixed and mailed as follows:

 BY FAX AND MAIL---

I personally sent to the addressee's telecopier number a true copy of the above described

document(s), and verified said transmission. Thereafter, I placed a true copy in a sealed

envelope with first class postage affixed and mailed as follows:

 BY PERSONAL SERVICE---

By causing delivered by hand to the addressee addressed as follows:

 BY FEDERAL EXPRESS - - -

By causing delivery by Federal Express of the document(s), before the time due for pick-up,

addressed as follows:

Stephen A. Bamberger

1529 Old Bridge Road, Suite 2

Woodbridge, VA 22192

Facsimile: (703) 499-9809

I declare under penalty of perjury that the foregoing is true and correct and that this

Declaration is executed on May 10, 2005, at Sacramento, California.

 Sarah J. Goodness /s/ 

Case 2:04-cv-01297-FCD-DAD Document 19 Filed 05/12/05 Page 4 of 4