On April 05, 2019 a
Stipulation,Agreement
was filed
involving a dispute between
Cpi Chico Beneficiary Llc,
Ta Chico Llc,
Hk Deluxe Llc,
and
Hk Deluxe Llc,
for civil
in the District Court of Butte County.
Preview
7/30/2020
I Daniel Fox, Esq. (SBN: 268757)
K&L Gates LLP
2 4 Embarcadero Center, Suite 1200
San Francisco, CA 94111
3 Telephone: 415.882.8200
Facsimile: 415.882.8220
4 daniel.fox@klgates.com
5 Daniel M. Eliades, Esq.(Admitted Pro Hae Vice)
Benjamin I. Rubinstein, Esq. (Admitted Pro Hae Vice)
6 K&L Gates LLP
One Newark Center, 10th Floor
7 Newark, NJ 07102
Telephone: 973.848.4018
8 Facsimile: 973.848.4001
daniel.eliades@klgates.com
9 benjamin.rubinstein@ldgates.com
10 Attorneys for Plaintiffs CPI CHICO BENEFICIARY LLC
and TA CHICO LLC
11
12 SUPERIOR COURT OF CALIFORNIA
13 COUNTY OF BUTfE
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15 CPI CHICO BENEFICIARY LLC and Case No.: 19CV01079
TA CHICO LLC,
16
Plaintiffs, JOINT STIPULATION AND
17 [PROPOSED] ORDER TO
v. CONTINUE THE HEARING DATE
18 ON DEFENDANT'S DEMURRER
HK DELUXE, LLC TO AMENDED COMPLAINT
19
20 Defendant.
Dept.: I
21 Judge: Hon. Tamara Mosbarger
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JOINT STIPULATION AND [PROPOSED) ORDER TO CONTINUE HEARING ON
Electronically Filed DEMURRER
307135130 vl
1 The parties in the above-entitled action previously met and conferred and, based on prospects
2 for settlement and the public health situation related to the COVID-19 pandemic and
3 mandates/guidance from government agencies and private enterprise regarding travel and group
4 gatherings (including, without limitation, the fact that the offices of certain counsel and parties have
5 been and remain subject to mandatory closure orders), agreed that certain motion hearing dates
6 should be further continued.
7 Accordingly, and subject to court order, the parties hereby stipulate to change the hearing
8 dates on the demurrer and the motion to strike as follows:
9
IO Event Current Date New Proposed Date
11 Hearing on Demurrer August 12, 2020 September 9, 2020
12 Hearing on Motion to Strike August 12, 2020 September 9, 2020
13 Motion deadlines will be calculated based on the new hearing dates.
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K&L Gates LLP
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Dated: July 28, 2020 By: /s/ Benjamin I. Rubinstein
20 Benjamin I. Rubinstein
21 Attorneys for Plaintiffs CPI CHICO
22 BENEFICIARY LLC and TA CHICO LLC
23
inn, A Professional Corporation
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25
Dated: July 28, 2020
26 Dennis M. Wilson
27 Attorneys for Defendant HK DELUXE, LLC
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JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING ON
DEMURRER
307135130 v 1
1 ORDER
2 GOOD CAUSE appearing, it is so ordered.
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Dated: By=~~~~~~~~~~~~~~
5 JUDGE OF TIIE SUPERIOR COURT
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IO
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JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING ON
DEMURRER
307135130 vl
Document Filed Date
August 03, 2020
Case Filing Date
April 05, 2019
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Preview
7/30/2020 I Daniel Fox, Esq. (SBN: 268757) K&L Gates LLP 2 4 Embarcadero Center, Suite 1200 San Francisco, CA 94111 3 Telephone: 415.882.8200 Facsimile: 415.882.8220 4 daniel.fox@klgates.com 5 Daniel M. Eliades, Esq.(Admitted Pro Hae Vice) Benjamin I. Rubinstein, Esq. (Admitted Pro Hae Vice) 6 K&L Gates LLP One Newark Center, 10th Floor 7 Newark, NJ 07102 Telephone: 973.848.4018 8 Facsimile: 973.848.4001 daniel.eliades@klgates.com 9 benjamin.rubinstein@ldgates.com 10 Attorneys for Plaintiffs CPI CHICO BENEFICIARY LLC and TA CHICO LLC 11 12 SUPERIOR COURT OF CALIFORNIA 13 COUNTY OF BUTfE 14 15 CPI CHICO BENEFICIARY LLC and Case No.: 19CV01079 TA CHICO LLC, 16 Plaintiffs, JOINT STIPULATION AND 17 [PROPOSED] ORDER TO v. CONTINUE THE HEARING DATE 18 ON DEFENDANT'S DEMURRER HK DELUXE, LLC TO AMENDED COMPLAINT 19 20 Defendant. Dept.: I 21 Judge: Hon. Tamara Mosbarger 22 23 24 25 26 27 28 JOINT STIPULATION AND [PROPOSED) ORDER TO CONTINUE HEARING ON Electronically Filed DEMURRER 307135130 vl 1 The parties in the above-entitled action previously met and conferred and, based on prospects 2 for settlement and the public health situation related to the COVID-19 pandemic and 3 mandates/guidance from government agencies and private enterprise regarding travel and group 4 gatherings (including, without limitation, the fact that the offices of certain counsel and parties have 5 been and remain subject to mandatory closure orders), agreed that certain motion hearing dates 6 should be further continued. 7 Accordingly, and subject to court order, the parties hereby stipulate to change the hearing 8 dates on the demurrer and the motion to strike as follows: 9 IO Event Current Date New Proposed Date 11 Hearing on Demurrer August 12, 2020 September 9, 2020 12 Hearing on Motion to Strike August 12, 2020 September 9, 2020 13 Motion deadlines will be calculated based on the new hearing dates. 14 15 16 17 K&L Gates LLP 18 19 Dated: July 28, 2020 By: /s/ Benjamin I. Rubinstein 20 Benjamin I. Rubinstein 21 Attorneys for Plaintiffs CPI CHICO 22 BENEFICIARY LLC and TA CHICO LLC 23 inn, A Professional Corporation 24 25 Dated: July 28, 2020 26 Dennis M. Wilson 27 Attorneys for Defendant HK DELUXE, LLC 28 1 JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING ON DEMURRER 307135130 v 1 1 ORDER 2 GOOD CAUSE appearing, it is so ordered. 3 4 Dated: By=~~~~~~~~~~~~~~ 5 JUDGE OF TIIE SUPERIOR COURT 6 7 8 9 IO 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING ON DEMURRER 307135130 vl