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Case No. 3:17-cv-00695-EMC JT. NTC. OF SETTLEMENT AND STIP. TO

VACATE/CONTINUE; AND [PROP.] ORDER

KRONENBERGER ROSENFELD, LLP 

Karl S. Kronenberger (Bar No. 226112)

Jeffrey M. Rosenfeld (Bar No. 222187)

Liana W. Chen (Bar No. 296965)

150 Post Street, Suite 520

San Francisco, CA 94108

Telephone: (415) 955-1155

Facsimile: (415) 955-1158

Karl@KRInternetLaw.com

Jeff@KRInternetLaw.com

Liana@KRInternetLaw.com 

Attorneys for Plaintiff NostalgiaConventions.com, LLC

dba Colossalcon

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

NOSTALGIACONVENTIONS.COM, LLC,

an Ohio limited liability company dba

COLOSSALCON,

Plaintiff,

v.

COLOSSUS CON aka COLOSSUS POP 

CULTURE EXPO & COMIC CON aka 

COLOSSUS POP EXPO, a business 

entity of unknown formation;

MARINA LUKYANTSEVA aka MARINA 

LUKYANTSEVA-HAWORTH, an individual 

dba COLOSSUS CON;

DAVIDSON HAWORTH, an individual dba 

COLOSSUS CON;

COLOSSUS GIRL ENTERTAINMENT 

LLC, a California limited liability company;

and DOES 1 through 10, inclusive,

Defendants.

Case No. 3:17-cv-00695-EMC

JOINT NOTICE OF SETTLEMENT 

AND STIPULATION TO VACATE 

AND CONTINUE UPCOMING 

HEARINGS; 

AND [PROPOSED] ORDER 
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Case No. 3:17-cv-00695-EMC 1 JT. NTC. OF SETTLEMENT AND STIP. TO

VACATE/CONTINUE; AND [PROP.] ORDER

The parties, Plaintiff NostalgiaConventions.com, LLC dba Colossalcon (“Plaintiff”), 

through counsel, and Defendants Marina Lukyantseva and Davidson Haworth 

(“Defendants”), hereby notify the Court that they have reached a settlement in principle. 

The parties’ settlement contemplates injunctive relief to be completed by October 1, 2017, 

and, if said injunctive relief is completed, the parties intend to thereafter stipulate to 

dismissal of the action with prejudice.

Therefore, to preserve the resources of the parties and the Court, the parties 

hereby stipulate and request that the Court: (1) vacate the upcoming hearing on 

Defendants’ Motion to Dismiss, currently scheduled for August 17, 2017, and (2) continue 

the upcoming status hearing, currently scheduled for September 14, 2017, to October 26, 

2017, or any convenient date thereafter.

IT IS SO STIPULATED.

Dated: August 7, 2017 KRONENBERGER ROSENFELD, LLP

 By: s/ Liana W. Chen______ 

 Liana W. Chen

Attorneys for Plaintiff 

Dated: August 7, 2017 DAVIDSON HAWORTH

By: s/ Davidson Haworth____

Defendant Pro Per

Dated: August 7, 2017 MARINA LUKYANTSEVA

By: s/ Marina Lukyantseva___

Defendant Pro Per

ATTESTATION OF CONCURRENCE IN FILING

Pursuant to Local Rule 5-1(i)(3), the filer hereby attests that concurrence in the filing 

of this document has been obtained from each of the other signatories, which shall serve 

in lieu of their signatures on the document.

 s/ Liana W. Chen____

Liana W. Chen
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Case No. 3:17-cv-00695-EMC 2 JT. NTC. OF SETTLEMENT AND STIP. TO

VACATE/CONTINUE; AND [PROP.] ORDER

[PROPOSED] ORDER

The Court, having considered the parties’ stipulation and finding good cause 

appearing, hereby orders:

1. The August 17, 2017 hearing on Defendants’ Motion to Dismiss is HEREBY 

VACATED.

2. The September 14, 2017 status hearing is HEREBY CONTINUED to October 

26, 2017 [or ________________________ ] at 10:30 a.m.

IT IS SO ORDERED.

Dated: ____________

UNITED STATES DISTRICT JUDGE

8/8/2017

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

AS MODIFIED

Judge Edward M. Chen