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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 October 31, 2005.

Magistrate Judge Dale Drozd’s order dated August 19, 2005 requiring Defendant Robert

Fraidenburgh to appear at a deposition in Northern California demonstrates “good cause” as required

for the modification of the Status Order.

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 October

31, 2005.

/ / /

/ / /

/ / /

Case 2:04-cv-01297-FCD-DAD Document 33 Filed 09/13/05 Page 1 of 4
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STIPULATION

WHEREFORE, Plaintiff and Defendant hereby stipulate and request that the June 30, 2005,

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

be completed by October 31, 2005.

IT IS SO STIPULATED.

Dated: ______________________. ______________________________

Shawn M. Krogh

Attorney for Defendant ROBERT B.

FRAIDENBURGH

Dated:_______________________. ______________________________

Stephen A. Bamberger

Attorney for Plaintiff IMPRIMIS

INTERNATIONAL, INC.

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STIPULATION

ORDER

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

June 30, 2005, close of discovery date. 

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

be completed by October 31, 2005.

IT IS FURTHER ORDERED in light of discovery the following dates are hereby reset:

dispositive motions must be heard no later than January 13, 2006 at 10:00 a.m. All briefing as to

the motions must be in compliance with Local Rule 78-230. The final pretrial conference is set

for Friday, March 17, 2006 at 2:30 p.m. The joint final pretrial statement shall be filed no later

than March 10, 2006. The parties shall refer to the court’s Status Order filed November 30, 2004

as to the form and content of the statement. The jury trial is reset to Tuesday, May 23, 2006 at 

9:00 a.m.

Dated: September 13, 2005 /s/ Frank C. Damrell Jr. 

Frank C. Damrell Jr.

U.S. 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_______________________ at Sacramento, California.

 Devika Datt ________________________

Case 2:04-cv-01297-FCD-DAD Document 33 Filed 09/13/05 Page 4 of 4