Case 2:18-cv-02217-SJO-FFM Document 36 Filed 04/12/18 Page 1 of 3 Page ID #:715

1 BLAKELY LAW GROUP

BRENT H. BLAKELY (CA Bar No. 157292)
1334 Parkview Avenue, Suite 280
3 Manhattan Beach, California 90266
Telephone: (310) 546-7400
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Facsimile: (310) 546-7401
5 Email:
BBlakely@BlakelyLawGroup.com
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Attorneys for Defendants
7 ESSENTIAL CONSULTANTS, LLC and
MICHAEL COHEN
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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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Case No. 2:18-CV-02217-SJO-FFM

12 STEPHANIE CLIFFORD a.k.a.

STORMY DANIELS a.k.a. PEGGY

13 PETERSON, an individual,
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Plaintiff,

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v.

17 DONALD J. TRUMP a.k.a. DAVID
18 DENNISON, an individual,

ESSENTIAL CONSULTANTS, LLC, a
Delaware Limited Liability Company,
20 MICHAEL COHEN, an individual, and
DOES 1 through 10, inclusive,
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STIPULATION OF ALL PARTIES
RE: DEFENDANTS’ EX PARTE
APPLICATION TO STAY ACTION
AND EXTENSION OF ALL
UPCOMING FILING DEADLINES
[Proposed Order Filed Concurrently
Herewith]
Assigned for All Purposes to the
Hon. S. James Otero
Action Filed: March 6, 2018

Defendants.

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STIPULATION

 Case 2:18-cv-02217-SJO-FFM Document 36 Filed 04/12/18 Page 2 of 3 Page ID #:716

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STIPULATION
Plaintiff Stephanie Clifford (“Plaintiff”) and Defendants Essential Consultants,

3 LLC (“EC”), Michael Cohen and Donald J. Trump (collectively, “Defendants”)
4 (together with Plaintiff, the “Parties”) hereby jointly agree and stipulate as follows:
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WHEREAS, Defendants intend to file an ex parte application to stay this

6 action on the grounds that an ongoing criminal investigation overlaps with the facts
7 of this case, and implicates Defendant Michael Cohen’s Fifth Amendment rights (the
8 “Ex Parte Application”).
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WHEREAS, Plaintiff does not believe there should be any stay or delay of this

10 case, and intends to vigorously oppose Defendants’ application.
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WHEREAS, the Parties have various upcoming filing deadlines relating to the

12 following motions: (1) EC’s Motion to Compel Arbitration, which was joined by Mr.
13 Trump; (2) Plaintiff’s Motion for Expedited Jury Trial and for Limited Expedited
14 Discovery; and (3) Mr. Cohen’s Motion to Strike or, Alternatively, Dismiss
15 Plaintiff’s First Amended Complaint (collectively, the “Motions”).
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WHEREAS, the Parties wish to allow the Court sufficient time to decide the

17 Ex Parte Application, while also affording them sufficient time to file their upcoming
18 briefs in connection with the Motions in the event the Court denies the Ex Parte
19 Application.
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WHEREAS, the Parties have not previously requested any extension of the

21 filing deadlines relating to the Motions.
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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by the

23 Parties, through their counsel of record, that:
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1.

Defendants shall have until 6:00 p.m. on Friday, April 13, 2018, to file

25 the Ex Parte Application.
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2.

Plaintiff shall have until 6:00 p.m. on Monday, April 16, 2018, to file

27 her opposition to the Ex Parte Application.
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3.

Defendants shall have until 6:00 p.m. on Tuesday, April 17, 2018, to file
-2STIPULATION

 Case 2:18-cv-02217-SJO-FFM Document 36 Filed 04/12/18 Page 3 of 3 Page ID #:717

1 their reply in support of the Ex Parte Application.
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4.

The due dates for all opposition and reply briefs in connection with the

3 Motions shall be extended by a period of seven (7) days.
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5 Dated: April 12, 2018

BLAKELY LAW GROUP

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By: /s/ Brent H. Blakely
BRENT H. BLAKELY
Attorneys for Defendants
ESSENTIAL CONSULTANTS, LLC and
MICHAEL COHEN

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11 Dated: April 12, 2018

HARDER LLP

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By: /s/ Charles J. Harder
CHARLES J. HARDER
Attorneys for Defendant
DONALD J. TRUMP

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Dated: April 12, 2018

AVENATTI & ASSOCIATES, APC

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By: /s/ Michael J. Avenatti
MICHAEL J. AVENATTI
Attorneys for Plaintiff
STEPHANIE CLIFFORD

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Pursuant to Local Rule 5-4.3.4, I Brent H. Blakely, hereby attest that all other
signatories to this Ex Parte Application, and on whose behalf it is submitted, concur
in its content and have authorized its filing.
Dated: April 12, 2018

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/s/ Brent H. Blakely
BRENT H. BLAKELY

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-3STIPULATION