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DIEPENBROCK 

HARRISON

ATTORNEYS AT LAW

EILEEN M. DIEPENBROCK – SBN 119254 

CHRIS A. McCANDLESS - SBN 210085 

DIEPENBROCK HARRISON 

A Professional Corporation 

400 Capitol Mall, Suite 1800 

Sacramento, CA 95814-4413 

Telephone: (916) 492-5000 

Facsimile: (916) 446-4535 

Attorneys for Defendant 

CAVIAR CREATOR, INC., a Nevada corporation

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

DANIEL W. FAERFERS and KATJA 

FAERFERS, 

Plaintiffs, 

v. 

CAVIAR CREATOR, INC., a Nevada 

corporation, individually and as successor 

to n Oregon corporation; CAVIAR 

CREATOR, INC., a Nevada corporation, 

Defendants 

AND RELATED COUNTERCLAIMS

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Case No.: 2:04–cv-2690-MCE-PAN 

STIPULATION AND ORDER RE: 

DATE TO SUBMIT JOINT PRETRIAL 

STATEMENT 

WHEREAS, the above-captioned action previously was set for trial on October 25, 

2006, pursuant to the Court’s scheduling Order dated September 20, 2005; 

WHEREAS in its September 20, 2005, scheduling order this Court also ordered a 

Final Pretrial Conference to occur on August 28, 2006, with a joint pretrial statement due on 

or before August 14, 2006; 

WHEREAS on January 6, 2006, this Court ordered modifications to the September 

20, 2006 scheduling order, including, among other modifications, setting a new trial date for 

January 24, 2007, and a new date for the Final Pretrial Conference on December 18, 2006; 

WHEREAS the Court did not expressly modify the date for submission of the joint 

pretrial statement, currently due on August 14, 2006; 

Case 2:04-cv-02690-TLN-EFB Document 121 Filed 07/06/06 Page 1 of 3
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DIEPENBROCK 

HARRISON

ATTORNEYS AT LAW

WHEREAS the Court’s Local Rules 16-281 provide that pretrial statements must be 

submitted not less than ten court days prior to the Final Pretrial Conference, which in this 

case is set for December 18, 2006; 

WHEREAS, the parties agree to submit a joint pretrial statement in accord with 

Local Rule 16-281 on or before December 4, 2006; 

THEREFORE, IT IS HEREBY STIPULATED by and between the parties hereto 

through their respective attorneys of record; Vaughan & Associates, Cris C. Vaughan, for 

Plaintiffs/counter-defendants Daniel W. Faerfers and Katja Faerfers, and Diepenbrock 

Harrison, Eileen M. Diepenbrock for Defendant/counterclaimant Caviar Creator, Inc., that 

the currently scheduled date for submission of the joint pretrial statement of August 14, 

2006, should be continued to December 4, 2006, ten court days prior to the Final Pretrial 

Conference. 

SO STIPULATED. 

DATED: June 29, 2006 DIEPENBROCK HARRISON 

 

By: 

 /s/ Eileen M. Diepenbrock 

 Eileen M. Depenbrock 

 Attorneys for Caviar Creator, Inc. 

DATED: June 28, 2006 VAUGHAN & ASSOCIATES 

 By: 

 /s/ Cris C. Vaughan 

 Cris C. Vaughan 

Attorneys for Plaintiffs DANIEL 

FAERFERS and KATJA FAEFERS 

Original Signatures maintained by 

Diepenbrock Harrison 

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DIEPENBROCK 

HARRISON

ATTORNEYS AT LAW

ORDER

PURSUANT TO STIPULATION, the currently scheduled date for submission of the 

joint pretrial statement pursuant to Local Rule 16-281 and this Court’s scheduling order 

dated September 20, 2005, is continued from August 14, 2006 to December 4, 2006. 

IT IS SO ORDERED. 

DATED: July 5, 2006

__________________________________ 

MORRISON C. ENGLAND, JR 

UNITED STATES DISTRICT JUDGE 

 

Case 2:04-cv-02690-TLN-EFB Document 121 Filed 07/06/06 Page 3 of 3