ESTTA Tracking number:
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`ESTTA1342776
`
`Filing date:
`
`02/27/2024
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Proceeding no.
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`92083405
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`Party
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`Correspondence
`address
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`Defendant
`Paige, LLC
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`JESSICA BROMALL SPARKMAN
`JEFFER MANGELS BUTLER & MITCHELL LLP
`1900 AVENUE OF THE STARS
`SEVENTH FLOOR
`LOS ANGELES, CA 90067-5010
`UNITED STATES
`Primary email: trademarkdocket@jmbm.com
`(310) 203-8080
`
`Submission
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`Filer's name
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`Filer's email
`
`Signature
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`Date
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`Response to Board Order/Inquiry
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`Jessica Bromall Sparkman
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`trademarkdocket@jmbm.com
`
`/Jessica Bromall Sparkman/
`
`02/27/2024
`
`Attachments
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`Response to Board Order and Exhibits.pdf(4280053 bytes )
`
`

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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`SHOP PAIGE LLC,
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`
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`Opposition No. 92083405
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`Petitioner,
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`Registration No. 5798838
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`v.
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`Mark: PAIGE
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`PAIGE, LLC,
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`Registrant.
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`Atty. Ref. No.: 66884-0269
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`PAIGE’S RESPONSE TO ORDER TO
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`SUBMIT COPY OF FEDERAL COURT PLEADINGS
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`Over a year ago, Paige filed a lawsuit against Petitioner for, inter alia, trademark
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`infringement, in the United States District Court for the Central District of California, entitled
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`Paige, LLC v. Shop Paige LLC, Case No. 2:22-cv-07800 (the “Civil Action”). U.S. Reg. No.
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`5798838 (the “858 Reg.”), cancellation of which is sought in the above-captioned proceeding, is
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`one of many registrations for PAIGE asserted by Registrant in the Civil Action. On February 6,
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`2024, the Board entered an order (the “Order”) deferring consideration of Paige’s Motion to
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`Dismiss or, Alternatively, for Summary Judgment (the “Motion”) and directing Paige to submit
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`copies of the pleadings in the Civil Action so that the Board can determine whether suspension
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`of this proceeding is warranted in view of the issues before the federal court in the Civil Action.
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`On February 16, 2024, the Court granted Paige’s Motion for Summary Judgment in its
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`entirety. The order granting summary judgment was issued under seal and, for that reason, no
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`copy is attached hereto. In view of its order, however, the Court vacated the trial date in the Civil
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`Action and ordered the parties to meet and confer regarding issuance of injunctive relief. A copy
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`of a Docket Report in the Civil Action reflecting the foregoing, see Docket Nos. 83-86 in
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`particualr, is attached hereto as Exhibit A.
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`

`

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`As directed by the Board, Paige also hereby submits copies of the following pleadings
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`and other documents from the Civil Action:
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`Exhibit B: Complaint of Plaintiff Paige, LLC
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`Exhibit C: Answer of Defendant Shop Paige, LLC
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`Exhibit D:
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`Joint Brief re Plaintiff Paige, LLC’s Motion for Summary Judgment
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`Exhibit E:
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`Plaintiff Paige, LLC’s Memorandum of Contentions of Fact and Law
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`Exhibit F: Notice of Lodging of [Proposed] Pretrial Conference Order field by
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`Plaintiff Paige, LLC
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`As is clear from the foregoing information and the attached documents, Petitioner has not
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`sought cancellation of the 858 Reg. in the Civil Action, nor has it asserted in the Civil Action –
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`by a counterclaim, affirmative defense, or otherwise – that the 858 Reg. is subject to cancellation
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`on any ground, let alone any of the grounds raised in petition. Thus, the outcome of the Civil
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`Action has no bearing on the proceeding presently before the Board.
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`Paige respectfully requests that Board decline to suspend this proceeding and grant
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`
`_/jessica bromall sparkman/
`Rod S. Berman, Esq.
`Jessica Bromall Sparkman, Esq.
`Jeffer Mangels Butler & Mitchell LLP
`1900 Avenue of the Stars, Seventh Floor
`Los Angeles, CA 90067-5010
`Telephone: (310) 203-8080
`Fax: (310) 203-0567
`E-mail: trademarkdocket@jmbm.com
`
`Attorneys for Registrant Paige, LLC
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`Paige’s Motion.
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`
`Dated: February 27, 2024
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`72007117v1
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`

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`EXHIBIT A
`EXHIBIT A
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`

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`2/27/24, 10:35 AM
`
`CM/ECF - California Central District
`ACCO,(SKx),AO120,DISCOVERY,MANADR
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA (Western Division - Los Angeles)
`CIVIL DOCKET FOR CASE #: 2:22-cv-07800-HDV-SK
`
`Paige, LLC v. Shop Paige LLC et al
`Assigned to: Judge Hernan D. Vera
`Referred to: Magistrate Judge Steve Kim
`Demand: $100,000
`Cause: 15:1114 Trademark Infringement
`Plaintiff
`Paige, LLC
`a California limited liability company
`
`Date Filed: 10/26/2022
`Jury Demand: Plaintiff
`Nature of Suit: 840 Trademark
`Jurisdiction: Federal Question
`
`represented by Jessica Bromall Sparkman
`Jeffer Mangels Butler and Mitchell LLP
`1900 Avenue of the Stars, 7th Floor
`Los Angeles, CA 90067-4308
`310-203-8080
`Fax: 310-203-0567
`Email: jsparkman@jmbm.com
`LEAD ATTORNEY
`ATTORNEY TO BE NOTICED
`
`Lena Streisand
`Jeffer Mangels Butler and Mitchell LLP
`1900 Avenue of the Stars 7th Floor
`Los Angeles, CA 90067
`310-203-8080
`Fax: 310-203-0567
`Email: Lstreisand@jmbm.com
`ATTORNEY TO BE NOTICED
`
`Rod S. Berman
`Jeffer Mangels Butler and Mitchell LLP
`1900 Avenue of the Stars, 7th Floor
`Los Angeles, CA 90067-4308
`310-203-8080
`Fax: 310-203-0567
`Email: rberman@jmbm.com
`ATTORNEY TO BE NOTICED
`
`Stanley M. Gibson
`Jeffer Mangels Butler and Mitchell LLP
`1900 Avenue of the Stars, 7th Floor
`Los Angeles, CA 90067-4308
`310-203-8080
`Fax: 310-203-0567
`Email: smg@jmbm.com
`ATTORNEY TO BE NOTICED
`
`V.
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`https://ecf.cacd.uscourts.gov/cgi-bin/DktRpt.pl?123537564533283-L_1_0-1
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`1/10
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`

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`2/27/24, 10:35 AM
`Defendant
`Shop Paige LLC
`a New York limited liability company
`
`CM/ECF - California Central District
`
`represented by Michael Alan Trauben
`Singh Singh and Trauben LLP
`400 South Beverly Drive Suite 240
`Beverly Hills, CA 90212
`310-856-9705
`Fax: 888-734-3555
`Email: mtrauben@singhtraubenlaw.com
`LEAD ATTORNEY
`ATTORNEY TO BE NOTICED
`
`Brian A. Bloom
`Tarter Krinsky and Drogin LLP
`910 Franklin Avenue
`Garden City, NY 11530
`516-701-0200
`Email: bbloom@tarterkrinsky.com
`PRO HAC VICE
`ATTORNEY TO BE NOTICED
`
`Defendant
`Does
`1 through 10, inclusive
`
`Date Filed
`10/26/2022
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`10/26/2022
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`10/26/2022
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`10/26/2022
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`10/26/2022
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`10/26/2022
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`10/26/2022
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`10/26/2022
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`10/26/2022
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`# Docket Text
`1 COMPLAINT Receipt No: ACACDC-34218222 - Fee: $402, filed by Plaintiff PAIGE,
`LLC. (Attorney Jessica Bromall Sparkman added to party PAIGE, LLC(pty:pla))(Bromall
`Sparkman, Jessica) (Entered: 10/26/2022)
`2 CIVIL COVER SHEET filed by Plaintiff PAIGE, LLC. (Bromall Sparkman, Jessica)
`(Entered: 10/26/2022)
`3 CORPORATE DISCLOSURE STATEMENT Plaintiff Paige, Llc Corporate Disclosure
`Statement filed by Plaintiff PAIGE, LLC identifying Plaintiff Paige, Llc Corporate
`Disclosure Statement as Corporate Parent. (Bromall Sparkman, Jessica) (Entered:
`10/26/2022)
`4 Request for Clerk to Issue Summons on Complaint (Attorney Civil Case Opening) 1 filed
`by Plaintiff PAIGE, LLC. (Bromall Sparkman, Jessica) (Entered: 10/26/2022)
`5 REPORT ON THE FILING OF AN ACTION Regarding a Patent or a Trademark (Initial
`Notification) filed by PAIGE, LLC. (Bromall Sparkman, Jessica) (Entered: 10/26/2022)
`6 CERTIFICATE of Interested Parties filed by Plaintiff PAIGE, LLC, (Bromall Sparkman,
`Jessica) (Entered: 10/26/2022)
`7 NOTICE OF ASSIGNMENT to District Judge Maame Ewusi-Mensah Frimpong and
`Magistrate Judge Steve Kim. (lh) (Entered: 10/26/2022)
`8 NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. (lh) (Entered:
`10/26/2022)
`9 Notice to Counsel Re Consent to Proceed Before a United States Magistrate Judge. (lh)
`(Entered: 10/26/2022)
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`https://ecf.cacd.uscourts.gov/cgi-bin/DktRpt.pl?123537564533283-L_1_0-1
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`2/10
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`

`

`2/27/24, 10:35 AM
`10/26/2022
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`11/08/2022
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`11/09/2022
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`12/02/2022
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`12/22/2022
`12/29/2022
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`01/03/2023
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`01/03/2023
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`01/05/2023
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`01/05/2023
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`01/11/2023
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`02/04/2023
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`02/06/2023
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`CM/ECF - California Central District
`10 21 DAY Summons Issued re Complaint (Attorney Civil Case Opening) 1 as to Defendant
`Shop Paige LLC. (lh) (Entered: 10/26/2022)
`11 CIVIL STANDING ORDER by Judge Maame Ewusi-Mensah Frimpong. (kd) (Entered:
`11/08/2022)
`12 PROOF OF SERVICE filed by Plaintiff Paige, LLC, served on October 29 2022. (Bromall
`Sparkman, Jessica) (Entered: 11/09/2022)
`13 First STIPULATION Extending Time to Answer the complaint as to Shop Paige LLC
`answer now due 12/21/2022, re Complaint (Attorney Civil Case Opening) 1 filed by
`Plaintiff Paige, LLC.(Bromall Sparkman, Jessica) (Entered: 12/02/2022)
`14 Letter from Paige Restivo (rolm) (Entered: 12/23/2022)
`15 MINUTES (IN CHAMBERS) by Judge Maame Ewusi-Mensah Frimpong. The Court
`hereby orders plaintiff (s) to show cause in writing no later than JANUARY 6, 2023 why
`this action should not be dismissed for lack of prosecution. (SEE DOCUMENT FOR
`FURTHER DETAILS.) (rolm) (Entered: 12/29/2022)
`16 ANSWER to Complaint (Attorney Civil Case Opening) 1 with JURY DEMAND filed by
`Defendant Shop Paige LLC.(Attorney Michael Alan Trauben added to party Shop Paige
`LLC(pty:dft))(Trauben, Michael) (Entered: 01/03/2023)
`17 ORDER SETTING SCHEDULING CONFERENCE by Judge Maame Ewusi-Mensah
`Frimpong. Scheduling Conference set for 3/9/2023 at 10:00 AM before Judge Maame
`Ewusi-Mensah Frimpong. (kd) (Entered: 01/03/2023)
`18 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Document RE: Answer to
`Complaint (Attorney Civil Case Opening) 16 . The following error(s) was/were found:
`Local Rule 7-1.1 no notice of interested parties. In response to this notice, the Court may:
`(1) order an amended or correct document to be filed; (2) order the document stricken; or
`(3) take other action as the Court deems appropriate. You need not take any action in
`response to this notice unless and until the Court directs you to do so. (yl) (Entered:
`01/05/2023)
`19 NOTICE of Interested Parties filed by Defendant Shop Paige LLC, identifying Shop Paige
`LLC and Paige, LLC. (Trauben, Michael) (Entered: 01/05/2023)
`20 TEXT ONLY ENTRY by Judge Maame Ewusi-Mensah Frimpong. On December 22, 2022,
`Defendant filed a letter with the Court requesting a thirty-day extension on the time to file
`a response to the Complaint. ECF No. 14 . However, on January 3, 2023, Defendant filed
`an Answer to the Complaint, thereby mooting the request. Accordingly, the Court
`dismisses Defendant's request as moot. IT IS SO ORDERED. THERE IS NO PDF
`DOCUMENT ASSOCIATED WITH THIS ENTRY. (kd) TEXT ONLY ENTRY (Entered:
`01/11/2023)
`21 APPLICATION of Non-Resident Attorney Brian A. Bloom to Appear Pro Hac Vice on
`behalf of Defendant Shop Paige LLC (Pro Hac Vice Fee - $500 Fee Paid, Receipt No.
`ACACDC-34742629) filed by Defendant Shop Paige LLC. (Attachments: # 1 Proposed
`Order) (Trauben, Michael) (Entered: 02/04/2023)
`22 NOTICE of Deficiency in Electronically Filed Pro Hac Vice Application RE:
`APPLICATION of Non-Resident Attorney Brian A. Bloom to Appear Pro Hac Vice on
`behalf of Defendant Shop Paige LLC (Pro Hac Vice Fee - $500 Fee Paid, Receipt No.
`ACACDC-34742629) 21 . The following error(s) was/were found: Proposed Order has not
`been flattened and is causing a corruption with the filing. (lt) (Entered: 02/06/2023)
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`https://ecf.cacd.uscourts.gov/cgi-bin/DktRpt.pl?123537564533283-L_1_0-1
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`3/10
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`

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`2/27/24, 10:35 AM
`02/06/2023
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`02/09/2023
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`02/23/2023
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`03/02/2023
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`03/06/2023
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`03/06/2023
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`05/23/2023
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`06/13/2023
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`06/13/2023
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`06/14/2023
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`CM/ECF - California Central District
`23 AMENDED DOCUMENT filed by Defendant Shop Paige LLC. Amendment to Notice of
`Deficiency in Electronically filed Pro Hac Vice Application (G-112C) - optional html form,
`22 (Trauben, Michael) (Entered: 02/06/2023)
`24 ORDER by Judge Maame Ewusi-Mensah Frimpong: granting 21 Non-Resident Attorney
`Brian A. Bloom APPLICATION to Appear Pro Hac Vice on behalf of Shop Paige LLC,
`designating Michael Alan Trauben as local counsel. (lom) (Entered: 02/09/2023)
`25 JOINT REPORT PURSUANT TO FED. R. CIV. P. 26(f) REPORT filed by Plaintiff Paige,
`LLC. (Bromall Sparkman, Jessica) (Entered: 02/23/2023)
`26 Joint REQUEST for Leave of Brian A. Bloom and Rod S. Berman to Appear for March 9,
`2023 Scheduling Conference via ZOOM filed by Defendant Shop Paige LLC.
`(Attachments: # 1 Proposed Order) (Trauben, Michael) (Entered: 03/02/2023)
`27 TEXT ONLY ENTRY by Judge Maame Ewusi-Mensah Frimpong. The Court takes the
`Scheduling Conference off calendar, with no appearances necessary on March 9, 2023. The
`Court will issue the Scheduling Order based solely on the parties filings pursuant to
`Federal Rule of Civil Procedure 16(b). The Joint Request for Leave of Brian A. Bloom and
`Rod S. Berman to Appear for March 9, 2023 Scheduling Conference via ZOOM is denied
`as moot. 26 IT IS SO ORDERED. THERE IS NO PDF DOCUMENT ASSOCIATED
`WITH THIS ENTRY. (kd) TEXT ONLY ENTRY (Entered: 03/06/2023)
`28 CIVIL TRIAL ORDER by Judge Maame Ewusi-Mensah Frimpong. The Scheduling
`Conference scheduled for March 9, 2023, is hereby VACATED. The Scheduling Order
`governing this action is set forth in the Schedule of Pretrial and Trial Dates chart. The Jury
`Trial is set for 3/11/2024 at 8:30 a.m. The Final Pretrial Conference is set for 2/21/2024 at
`9:00 a.m. The last date to hear motion to amend pleadings or add parties is 4/27/2023. The
`discovery cut-off is 10/11/2023. The last date to hear motions due by 11/30/2023. The last
`date to conduct settlement conference is 12/13/2024.Stipulations extending dates set by the
`Court are not effective unless approved by the Court, and without compelling factual
`support and a showing of due diligence, stipulations continuing dates set by the Court will
`be denied. IT IS SO ORDERED. (See document for further details) (yl) (Entered:
`03/07/2023)
`29 REQUEST TO SUBSTITUTE ATTORNEY Brian A. Bloom, Tarter Krinsky & Drogin
`LLP in place of attorney Brian A. Bloom, Moritt Hock & Hamroff LLP filed by Defendant
`Shop Paige LLC. (Attachments: # 1 Proposed Order) (Trauben, Michael) (Entered:
`05/23/2023)
`30 NOTICE OF MOTION AND MOTION to Compel Discovery Responses and Production
`of Documents & Request for Sanctions filed by Plaintiff Paige, LLC. Motion set for
`hearing on 7/5/2023 at 10:00 AM before Magistrate Judge Steve Kim. (Attachments: # 1
`Bloom Declaration re Defendant's Portion of Joint Stipulation re Motion to Compel, # 2
`Sparkman Declaration ISO Motion to Compel with Exhibits, # 3 Joint Stipulation re
`Motion to Compel)(Bromall Sparkman, Jessica) (Entered: 06/13/2023)
`31 ORDER by Judge Maame Ewusi-Mensah Frimpong: GRANTING 29 Request to
`Substitute Attorney Brian A. Bloom at Tart Krinsky & Drogin LLP to Brian A. Bloom at
`Moritt Hock & Hamroff LLP. (yl) (Entered: 06/13/2023)
`32 MINUTES (IN CHAMBERS) ORDER GRANTING IN PART AND DENYING IN PART
`PLAINTIFF'S MOTION TO COMPEL [ECF 30 ] by Magistrate Judge Steve Kim. The
`hearing on this motion (as such) noticed for July 5, 2023 at 10 AM is vacated. But, as
`noted, that date and time may be reopened for an informal discovery conference if one is
`needed and properly requested through the court's published procedures. (SEE ORDER
`FOR DETAILS). (clee) (Entered: 06/14/2023)
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`https://ecf.cacd.uscourts.gov/cgi-bin/DktRpt.pl?123537564533283-L_1_0-1
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`4/10
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`2/27/24, 10:35 AM
`06/20/2023
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`06/23/2023
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`06/28/2023
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`07/03/2023
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`07/03/2023
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`07/05/2023
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`07/05/2023
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`07/05/2023
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`07/05/2023
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`07/10/2023
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`07/10/2023
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`07/10/2023
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`CM/ECF - California Central District
`33 ORDER OF THE CHIEF JUDGE (#23-068) approved by Judge Philip S. Gutierrez.
`Pursuant to the recommended procedure adopted by the Court for the CREATION OF
`CALENDAR of Judge Hernan D. Vera, this case is transferred from Judge Maame Ewusi-
`Mensah Frimpong to the calendar of Judge Hernan D. Vera for all further proceedings. The
`case number will now reflect the initials of the transferee Judge 2:22-cv-07800-HDV-SKx.
`(rn) (Entered: 06/21/2023)
`34 REASSIGNMENT ORDER by Judge Hernan D. Vera: Please refer to Order for complete
`details. (cbr) (Entered: 06/23/2023)
`35 NOTICE OF MOTION AND MOTION for Reconsideration re Order on Motion to
`Compel, 32 filed by Plaintiff Paige, LLC. Motion set for hearing on 8/2/2023 at 10:00 AM
`before Magistrate Judge Steve Kim. (Attachments: # 1 Memorandum of Points and
`Authorities in Support of Motion for Reconsideration, # 2 Declaration of Jessica Bromall
`Sparkman in Support of Motion for Reconsideration) (Bromall Sparkman, Jessica)
`(Entered: 06/28/2023)
`36 SCHEDULING NOTICE by Magistrate Judge Steve Kim re: NOTICE OF MOTION AND
`MOTION for Reconsideration re Order on Motion to Compel, 32 35 . The hearing on
`motion is ADVANCED to Wednesday, July 5, 2023 at 3:00 PM and will be held via Zoom
`videoconference. Any opposition to the motion is due by July 5, 2023 at 11:00 AM. Judge
`Kim's Zoom Webinar information can be found on his page on the court's website
`(http://www.cacd.uscourts.gov/honorable-steve-kim). Counsel should log in 10 minutes
`early to allow time to check in and test audio/video. THERE IS NO PDF DOCUMENT
`ASSOCIATED WITH THIS ENTRY. (clee) TEXT ONLY ENTRY (Entered: 07/03/2023)
`37 Joint STIPULATION for Protective Order filed by Defendant Shop Paige LLC.
`(Attachments: # 1 Proposed Order)(Trauben, Michael) (Entered: 07/03/2023)
`38 OPPOSITION to NOTICE OF MOTION AND MOTION for Reconsideration re Order on
`Motion to Compel, 32 35 filed by Defendant Shop Paige LLC. (Attachments: # 1
`Declaration)(Trauben, Michael) (Entered: 07/05/2023)
`39 REPLY in Support of NOTICE OF MOTION AND MOTION for Reconsideration re
`Order on Motion to Compel, 32 35 filed by Plaintiff Paige, LLC. (Attachments: # 1
`Declaration of Jessica Bromall Sparkman in Support of Motion for Reconsideration)
`(Bromall Sparkman, Jessica) (Entered: 07/05/2023)
`40 STIPULATED PROTECTIVE ORDER 37 by Magistrate Judge Steve Kim. (clee)
`(Entered: 07/05/2023)
`41 MINUTES OF PLAINTIFF'S MOTION FOR RECONSIDERATION OF ORDER RE:
`MOTION TO COMPEL denying 35 MOTION for Reconsideration; Motion Hearing held
`before Magistrate Judge Steve Kim. By no later than Wednesday, July 12, 2023, Defendant
`is ordered to produce all profit and loss statements from the years 2018 through 2022. (see
`document for further details) Court Recorder: CS 07/05/23. (hr) (Entered: 07/05/2023)
`42 STATEMENT OF JOINT CASE MANAGEMENT filed by Plaintiff Paige, LLC (Bromall
`Sparkman, Jessica) (Entered: 07/10/2023)
`43 NOTICE of Appearance filed by attorney Lena Streisand on behalf of Plaintiff Paige, LLC
`(Attorney Lena Streisand added to party Paige, LLC(pty:pla))(Streisand, Lena) (Entered:
`07/10/2023)
`44 ORDER RE REMOTE SETTLEMENT CONFERENCE WITH U.S. MAGISTRATE
`JUDGE KIM by Magistrate Judge Steve Kim. The Settlement Conference scheduled for
`Wednesday, September 13, 2023 at 10:00 AM shall take place remotely via Zoom video
`meeting. (see document for further details) (hr) (Entered: 07/11/2023)
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`https://ecf.cacd.uscourts.gov/cgi-bin/DktRpt.pl?123537564533283-L_1_0-1
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`5/10
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`2/27/24, 10:35 AM
`07/26/2023
`08/21/2023
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`08/22/2023
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`09/13/2023
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`09/27/2023
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`09/28/2023
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`10/23/2023
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`10/25/2023
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`11/02/2023
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`11/02/2023
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`CM/ECF - California Central District
`45 CIVIL STANDING ORDER by Judge Hernan D. Vera. (cbr) (Entered: 07/26/2023)
`46 Joint STIPULATION to AMEND Order,,,, Set/Reset Deadlines/Hearings,,, 28 filed by
`Plaintiff Paige, LLC. (Attachments: # 1 Proposed Order)(Streisand, Lena) (Entered:
`08/21/2023)
`47 ORDER MODIFYING SCHEDULING ORDER 46 by Judge Hernan D. Vera. The Court
`HEREBY ORDERS that the Scheduling Order entered in this case on March 6, 2023 (ECF
`No. 28) is modified as follows: Fact Discovery Cut-Off 10/6/23; Expert Disclosure (Initial)
`10/13/23; Expert Disclosure (Rebuttal) 10/27/23; Expert Discovery Cut-Off 11/13/23; Last
`Day to Hear Motions 12/14/23. (lom) (Entered: 08/22/2023)
`48 SCHEDULING NOTICE by Magistrate Judge Steve Kim. The Settlement Conference
`previously set for September 13, 2023 is CONTINUED to November 8, 2023 at 10:00 AM
`before before Magistrate Judge Steve Kim. THERE IS NO PDF DOCUMENT
`ASSOCIATED WITH THIS ENTRY. (clee) TEXT ONLY ENTRY (Entered: 09/13/2023)
`49 Joint STIPULATION for Hearing re SETTLEMENT CONFERENCE filed by Plaintiff
`Paige, LLC. (Attachments: # 1 Proposed Order RE JOINT STIPULATION TO SET
`SETTLEMENT CONFERENCE FOR NOVEMBER 8, 2023)(Bromall Sparkman, Jessica)
`(Entered: 09/27/2023)
`50 MINUTES (IN CHAMBERS) ORDER SETTING SETTLEMENT CONFERENCE by
`Magistrate Judge Steve Kim. The November 8, 2023 settlement conference in this matter
`(at 10 AM PT) will be held virtually via Zoom on the understanding that Paige, LLC
`representatives Paige Adams-Geller and Walter Lacher will both be present the entire
`duration of the remote conference unless expressly excused by the court. Meanwhile, the
`parties are ordered to continue good-faith settlement discussions (to include the exchange
`of pertinent financial information whether by formal or informal discovery) and to submit
`updated confidential settlement conference statements (ex parte via email to
`sk_chambers@cacd.uscourts.gov) by no later than 2 PM PT on October 25, 2023. Except
`as otherwise modified here, the terms of the courts previous order setting this conference
`remains in effect, including its provision authorizing sanctions if any party or counsel fails
`to comply with the order or fails to negotiate in good faith during the conference. (ECF 44
`). Zoom instructions will be disseminated separately by the court clerk. (clee) (Entered:
`09/28/2023)
`51 Joint STIPULATION to AMEND Order,, Set/Reset Deadlines/Hearings,, Terminate
`Deadlines and Hearings, 47 filed by Plaintiff Paige, LLC. (Attachments: # 1 Proposed
`Order to Modify Scheduling Order)(Bromall Sparkman, Jessica) (Entered: 10/23/2023)
`52 TEXT ONLY ENTRY (In Chambers) by Judge Hernan D. Vera: The Court has received
`and reviewed the parties' Joint Stipulation to Amend [Scheduling] Order 51 . The Court
`finds that good cause has not been shown and for that reason denies the relief requested.
`THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (wm) TEXT
`ONLY ENTRY (Entered: 10/25/2023)
`53 NOTICE OF MOTION AND MOTION for Summary Judgment filed by Plaintiff Paige,
`LLC. Motion set for hearing on 12/14/2023 at 10:00 AM before Judge Hernan D. Vera.
`(Bromall Sparkman, Jessica) (Entered: 11/02/2023)
`54 MEMORANDUM in Support of NOTICE OF MOTION AND MOTION for Summary
`Judgment 53 Joint Brief and Supporting Documents filed by Plaintiff Paige, LLC.
`(Attachments: # 1 Plaintiff's Statement of Uncontroverted Facts and Conclusions of Law, #
`2 Defendant's Statement of Genuine Issues and Plaintiff's Response Thereto, # 3 Appendix
`of Declarations and Written Evidence, # 4 Declaration of Walter Lacher, # 5 Declaration of
`Lena Streisand, # 6 Exhibit C, # 7 Exhibit D, # 8 Exhibit E, # 9 Exhibit F, # 10 Exhibit G,
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`11/02/2023
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`11/06/2023
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`11/08/2023
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`11/13/2023
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`01/02/2024
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`# 11 Exhibit H, # 12 Exhibit I, # 13 Exhibit J, # 14 Exhibit K, # 15 Exhibit L, # 16 Exhibit
`M, # 17 Exhibit N, # 18 Exhibit O, # 19 Exhibit P, # 20 Exhibit Q, # 21 Exhibit R, # 22
`Exhibit S, # 23 Exhibit T, # 24 Exhibit U, # 25 Exhibit V, # 26 Exhibit W, # 27 Exhibit X, #
`28 Exhibit Y, # 29 Exhibit Z, # 30 Exhibit AA, # 31 Exhibit AB, # 32 Exhibit AC, # 33
`Exhibit AD, # 34 Exhibit AE, # 35 Declaration of Paige Restivo, # 36 Exhibit AF, # 37
`Declaration of Lean Streisand (Supplemental), # 38 Exhibit AG, # 39 Exhibit AH, # 40
`Exhibit AI, # 41 Exhibit AJ, # 42 Exhibit AK, # 43 Exhibit AL, # 44 Exhibit AM, # 45
`Exhibit AN, # 46 Plaintiff's Evidentiary Objections, # 47 Proposed Order re Plaintiff's
`Evidentiary Objections, # 48 Proposed Order re MSJ)(Bromall Sparkman, Jessica)
`(Entered: 11/02/2023)
`55 APPLICATION to file document under seal filed by Plaintiff Paige, LLC. (Attachments: #
`1 Exhibit 1, # 2 Redacted Document Exhibit 6, # 3 Redacted Document Exhibit 7, # 4
`Redacted Document Exhibit 9, # 5 Proposed Order)(Bromall Sparkman, Jessica) (Entered:
`11/02/2023)
`56 SEALED DECLARATION IN SUPPORT OF APPLICATION to file document under seal
`55 filed by Plaintiff Paige, LLC. (Attachments: # 1 Unredacted Document [Sealed] Exhibit
`2, # 2 Unredacted Document [Sealed] Exhibit 3, # 3 Unredacted Document [Sealed]
`Exhibit 4, # 4 Unredacted Document [Sealed] Exhibit 5, # 5 Unredacted Document
`[Sealed] Exhibit 8)(Bromall Sparkman, Jessica) (Entered: 11/03/2023)
`57 TEXT ONLY ENTRY (In Chambers) by Judge Hernan D. Vera: The Court continues the
`hearing for Plaintiff's Motion for Summary Judgment 53 to 01/18/24 at 10am. THERE IS
`NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (wm) TEXT ONLY ENTRY
`(Entered: 11/03/2023)
`58 ORDER GRANTING PLAINTIFF PAIGE, LLC'S UNOPPOSED APPLICATION FOR
`LEAVE TO FILE DOCUMENTS UNDER SEAL 55 by Judge Hernan D. Vera. The Court
`hereby GRANTS Plaintiff Paige, LLC leave to file the following documents under seal: 1.
`Unredacted Joint Brief re Plaintiff Paige, LLC's Motion for Summary Judgment - Sealed.
`Plaintiff to publicly file a redacted copy. 2. Unredacted Declaration of Walter Lacher in
`support of Plaintiff Paige, LLC's Motion for Summary Judgment - Sealed. Plaintiff to
`publicly file a redacted copy. 3. Exhibit A to the Declaration of Walter Lacher in support of
`Plaintiff Paige, LLC's Motion for Summary Judgment - Sealed in its entirety. 4. Exhibit B
`to the Declaration of Walter Lacher in support of Plaintiff Paige, LLC's Motion for
`Summary Judgment - Sealed in its entirety. (lom) (Entered: 11/04/2023)
`59 SEALED DOCUMENT re Memorandum in Support of Motion,,,,, 54 , Order on Motion
`for Leave to File Document Under Seal,,, 58 filed by Plaintiff Paige, LLC. (Attachments: #
`1 Unredacted Document, # 2 Unredacted Document, # 3 Unredacted Document, # 4
`Unredacted Document)(Streisand, Lena) (Entered: 11/06/2023)
`60 MINUTES OF SETTLEMENT CONFERENCE held before Magistrate Judge Steve Kim.
`Held via Zoom videoconference. Case called. Counsel state their appearances for the
`record. The parties are reminded that recording, streaming, broadcasting, or screen
`capturing of any kind is prohibited, and that sanctions may be imposed for those found in
`violation. The Court and parties conduct settlement discussions off the record. The parties
`are advised that all discussions were, and are, deemed to be confidential settlement
`discussions. The Court shall provide a mediator's proposal for the parties consideration on
`November 9, 2023. Court Recorder: CS 11/08/23. (clee) (Entered: 11/09/2023)
`61 STATUS REPORT RE: SETTLEMENT CONFERENCE filed by Plaintiff Paige, LLC.
`(Bromall Sparkman, Jessica) (Entered: 11/13/2023)
`62 REQUEST to Continue Hearing on Plaintiff's Motion for Summary Judgment [ECF 53]
`from January 18, 2024 to February 1, 2024 Re: NOTICE OF MOTION AND MOTION for
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`2/27/24, 10:35 AM
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`01/02/2024
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`Summary Judgment 53 filed by Defendant Shop Paige LLC. (Attachments: # 1 Declaration
`of Brian A. Bloom, # 2 Proposed Order) (Trauben, Michael) (Entered: 01/02/2024)
`[AMENDED DECLARATION OF BRIAN A. BLOOM IN SUPPORT OF
`DEFENDANT'S REQUEST FOR A TWO-WEEK CONTINUANCE OF THE JANUARY
`18, 2024 HEARING ON PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT [ECF
`53] AND FOR LEAD COUNSEL FOR DEFENDANT TO BE ALLOWED TO APPEAR
`VIA ZOOM AT THE HEARING ON PLAINTIFF'S MOTION FOR SUMMARY
`JUDGMENT filed as] Amendment to REQUEST to Continue Hearing on Plaintiff's
`Motion for Summary Judgment [ECF 53] from January 18, 2024 to February 1, 2024 Re:
`NOTICE OF MOTION AND MOTION for Summary Judgment 53 62 filed by Defendant
`Shop Paige LLC. (Attachments: # 1 Exhibit "A")(Trauben, Michael) Modified on 1/2/2024
`(lom). (Entered: 01/02/2024)
`64 ORDER RE: DEFENDANT'S REQUEST FOR A TWO-WEEK CONTINUANCE OF
`THE JANUARY 18, 2024 HEARING ON PLAINTIFF'S MOTION FOR SUMMARY
`JUDGMENT [ECF 53] AND APPROVING COUNSEL FOR DEFENDANT'S REQUEST
`TO APPEAR VIA ZOOM AT THE HEARING ON PLAINTIFF'S MOTION FOR
`SUMMARY JUDGMENT 62 by Judge Hernan D. Vera. The Court hereby GRANTS the
`request to continue the Hearing on Plaintiff's motion for summary judgment [ECF 53],
`hereby continuing the hearing for Plaintiff's Motion for Summary Judgment to January 25,
`2024 at 10:00 a.m. In addition, the Court further GRANTS the request for lead counsel for
`Defendant, Brian A. Bloom, to appear at the Hearing on Plaintiff's motion for summary
`judgment via ZOOM. Lead counsel for Defendant, Brian A. Bloom, may appear at Hearing
`on Plaintiff's motion for summary judgment via ZOOM in accordance with the Court's
`procedures. (lom) Modified on 1/4/2024 (lom). (Entered: 01/04/2024)
`65 NOTICE OF MOTION AND MOTION to Exclude Defendant's Expert Witness Barry L.
`Bell filed by Plaintiff Paige, LLC. Motion set for hearing on 2/21/2024 at 09:00 AM before
`Judge Hernan D. Vera. (Attachments: # 1 Memorandum of Points and Authorities, # 2
`Declaration of Lena Streisand, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, #
`7 Exhibit E, # 8 Exhibit F, # 9 Exhibit G, # 10 Exhibit H, # 11 Exhibit I) (Streisand, Lena)
`(Entered: 01/23/2024)
`66 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Document RE: NOTICE
`OF MOTION AND MOTION to Exclude Defendant's Expert Witness Barry L. Bell 65 .
`The following error(s) was/were found: Proposed document was not submitted or was not
`submitted as a separate attachment. Other error(s) with document(s): No [Prop] Order. In
`response to this notice, the Court may: (1) order an amended or correct document to be
`filed; (2) order the document stricken; or (3) take other action as the Court deems
`appropriate. You need not take any action in response to this notice unless and until the
`Court directs you to do so. (lom) (Entered: 01/23/2024)
`[PROPOSED] ORDER GRANTING PLAINTIFF PAIGE, LLC'S MOTION TO
`EXCLUDE DEFENDANT SHOP PAIGE LLC'S EXPERT WITNESS BARRY L. BELL
`re NOTICE OF MOTION AND MOTION to Exclude Defendant's Expert Witness Barry L.
`Bell 65 filed by Plaintiff Paige, LLC. (Streisand, Lena) (Entered: 01/23/2024)
`68 STRICKEN, see docket entry no. 76 - Notice OF WITHDRAWAL OF JURY DEMAND
`filed by Plaintiff Paige, LLC. (Streisand, Lena) Modified on 1/29/2024 (lom). (Entered:
`01/23/2024)
`69 EXT ONLY ENTRY (IN CHAMBERS) ORDER by Judge Hernan D. Vera: The Court
`resets the Motion to Exclude 65 to 02/14/2024 at 10:00 AM. THERE IS NO PDF
`DOCUMENT ASSOCIATED WITH THIS ENTRY. (wm) TEXT ONLY ENTRY (Entered:
`01/24/2024)
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`67
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`2/27/24, 10:35 AM
`01/24/2024
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`01/24/2024
`01/24/2024
`01/25/2024
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`01/25/2024
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`CM/ECF - California Central District
`70 MEMORANDUM of CONTENTIONS of FACT and LAW filed by Plaintiff Paige, LLC.
`(Streisand, Lena) (Entered: 01/24/2024)
`71 JOINT Exhibit List filed by Plaintiff Paige, LLC.. (Streisand, Lena) (Entered: 01/24/2024)
`72 Witness List filed by Plaintiff Paige, LLC.. (Streisand, Lena) (Entered: 01/24/2024)
`73 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Document RE: Notice
`(Other) 68 . The following error(s) was/were found: Incorrect event selected. Correct event
`to be used is: Request - Order. Proposed document was not submitted or was not submitted
`as a separate attachment. Other error(s) with document(s): No [Prop] Order. In response to
`this notice, the Court may: (1) order an amended or correct document to be filed; (2) order
`the document stricken; or (3) take other action as the Court deems appropriate. You need
`not take any action in response to this notice unless and until the Court directs you to do
`so. (lom) (Entered: 01/25/2024)
`74 MINUTES OF PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT 53 Hearing held
`before Judge Hernan D. Vera. Arguments by counsel are heard. The Court takes the matter
`under submission. An order will issue. Court Reporter: Laura Elias. (lom) (Entered:
`01/25/2024)
`75 TRANSCRIPT ORDER as to Plaintiff Paige, LLC for Court Reporter. Court will contact
`Itzi Munoz at im3@jmbm.com with further instructions regarding this order. Transcript
`preparation will not begin until payment has been satisfied with the court reporter. (Gibson,
`Stanley) (Entered: 01/25/2024)
`76 ORDER TO STRIKE ELECTRONICALLY FILED DOCUMENT(S) by Judge Hernan D.
`Vera: the following document(s) be STRICKEN for failure to comply with the Local
`Rules, General Order and/or the Courts Case Management Order: Notice of Withdrawal of
`Jury Demand 68 , for the following reasons: Incorrect event selected. Correct event is:
`Request-Order. Proposed Document was not submitted as separate attachment. Requires
`proposed order. (lom) (Entered: 01/29/2024)
`77 OPPOSITION to NOTICE OF MOTION AND MOTION to Exclude Defendant's Expert
`Witness Barry L. Bell 65 filed by Defendant Shop Paige LLC. (Attachments: # 1
`Declaration of Brian A. Bloom, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C)(Trauben,
`Michael) (Entered: 01/31/2024)
`78 NOTICE OF LODGING Propos