Asiana Airlines et al v. Swissport USA, Inc. et al

Filing 52

STIPULATED JUDGMENT AGAINST CEED SECURITY INC by Judge George H Wu, IT IS STIPULATED AND AGREED by and between plaintiffs and Ceed Security that judgment is hereby entered against Ceed Security, Inc. in the amount of Forty Thousand Dollars ($40,000), less credit for payments already made, andthat post-judgment interest shall be awarded from the date of entry of judgme 48 (pj)

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Kevin R. Sutherland (State Bar No.: 163746) Michael A. Hession (State Bar No.: 219103) Geneva A. Collins (State Bar No.: 187023) CLYDE & CO US LLP 101 Second Street, 24th Floor San Francisco, California 94105 Telephone: [phone] Facsimile: [phone] Email: [e-mail] [e-mail] [e-mail] Attorneys for Plaintiffs and Counter-Defendant ASIANA AIRLINES, AIG EUROPE (UK) LIMITED and LIG INSURANCE CO., LTD. UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA ASIANA AIRLINES, AIG EUROPE ) (UK) LIMITED, and LIG ) INSURANCE CO., LTD., ) ) Plaintiffs, ) ) vs. ) ) SWISSPORT USA, INC.; ) SWISSPORT INTERNATIONAL ) LTD.; CLARK/MCCARTHY A ) JOINT VENTURE, CLARK ) CONSTRUCTION GROUP ­ ) CALIFORNIA, LP, MCCARTHY ) BUILDING COMPANIES, INC.; ) CEED SECURITY, INC.; THE CITY ) OF LOS ANGELES, LOS ANGELES ) WORLD AIRPORT; and ) FLORENTINO MENDES, ) ) ) Defendants, ) ) AND RELATED CROSS-ACTIONS. ) ) Case No.: CV-09-1137-GW(RZx) STIPULATED JUDGMENT AGAINST CEED SECURITY, INC.

Plaintiffs, by and through their attorneys, Clyde & Co US LLP, and Ceed Security, Inc. ("Ceed Security") by and through its attorneys, Law Offices of Robert Mobasseri, hereby agree and stipulate as follows:
STIPULATED JUDGMENT AGAINST CEED SECURITY, INC. [PROPOSED]

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101 Second Sreet, 24th Floor San Francisco, California 94105 Telephone: [phone]

WHEREAS, plaintiffs brought this action against Ceed Security, Inc. on February 17, 2009; and WHEREAS, plaintiffs settled their claims against Ceed Security, Inc. at a mediation conducted on October 12 and 13, 2009; and WHEREAS, the terms of the settlement between plaintiffs and Ceed Security, Inc. are set forth in the Stipulation and Order Re Entry of Judgment in the Event of Default, signed by counsel for plaintiffs and counsel for Ceed Security, Inc. and filed in this Court; WHEREAS, in accordance with the terms of the Stipulation and Order Re Entry of Judgment, plaintiffs may request entry of judgment in the sum of Forty Thousand Dollars ($40,000), less credit for payments already made, against Ceed Security, Inc. in the event Ceed Security, Inc. defaults on its obligations contained in the Stipulation and Order Re Entry of Judgment in the Event Default; and WHEREAS, plaintiffs and Ceed Security, Inc. hereby agree that plaintiffs shall hold this Stipulated Judgment in trust, and that plaintiffs shall file this Stipulated Judgment with the Court only in the event Ceed Security, Inc. defaults on its obligations under the Stipulation and Order Re Entry of Judgment in the Event of Default; IT IS STIPULATED AND AGREED by and between plaintiffs and Ceed Security that judgment is hereby entered against Ceed Security, Inc. in the amount of Forty Thousand Dollars ($40,000), less credit for payments already made, and that post-judgment interest shall be awarded from the date of entry of judgment. // // // // // //
STIPULATED JUDGMENT AGAINST CEED SECURITY, INC. [PROPOSED]

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CLYDE & CO US LLP

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LA09CV01137GW-O.3.doc

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101 Second Sreet, 24th Floor San Francisco, California 94105 Telephone: [phone]

IT IS SO STIPULATED. Dated: ____________, 2009 CLYDE & CO US LLP By: KEVIN R. SUTHERLAND MICHAEL A. HESSION GENEVA A. COLLINS Attorneys for Plaintiffs and Counter-Defendant ASIANA AIRLINES, AIG EUROPE (UK) LIMITED and LIG INSURANCE CO., LTD. Dated: ____________, 2009 ROBERT B. MOBASSERI LAW OFFICES By: ROBERT B. MOBASSERI Attorneys for Defendant CEED SECURITY, INC.

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CLYDE & CO US LLP

IT IS SO ORDERED. Dated: January 29, 2010 ______________________________________ HONORABLE GEORGE H. WU United States District Judge

LA09CV01137GW-O.3.doc

STIPULATED JUDGMENT AGAINST CEED SECURITY, INC. [PROPOSED]

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101 Second Sreet, 24th Floor San Francisco, California 94105 Telephone: [phone]

PROOF OF SERVICE I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is 101 Second Street, 24th Floor, San Francisco, California 94105. On January 25, 2010, I served the within documents: STIPULATED JUDGMENT AGAINST CEED SECURITY, INC. (By Mail): As Follows: I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at San Francisco, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than on day after the date of deposit for mailing in affidavit (By CM/ECF: I caused to be electronically filed a true and correct copy of the above-entitled document(s) with the Clerk of the Court using Case Management Filing (CM/ECF), which will send notification that such filing is available for viewing and downloading to all counsel on record electronically as required by the Court on this matter. (BY FAX) by transmitting via facsimile the document(s) listed above to the fax number(s) set forth below, or as stated on the attached service list, on this date before 5:00 p.m. (BY PERSONAL SERVICE) I caused such envelope(s) to be delivered by hand this date to the offices of the addressee(s). (BY OVERNIGHT DELIVERY) I caused such envelope(s) to be delivered to an overnight delivery carrier with delivery fees provided for, addressed to the person(s) on whom it is to be served.
Florentino Mendes 334 West 55th Street Los Angeles, California 90037 Garth W. Aubert, Esq. MENDES & MOUNT, LLP 445 South Figueroa Street, 38th Floor Los Angeles, California 90071 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail] Mark L. Kiefer, Esq. ERICKSEN ARBUTHNOT 835 Wilshire Boulevard, Suite 500 Los Angeles, California 90017 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail]
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CLYDE & CO US LLP

Defendant in Propria Persona

Attorneys for Defendant Swissport USA, Inc.

Attorney for Defendants Clark/McCarthy, A Joint Venture Clark Construction Group-California, LP McCarthy Building Companies, Inc. The City of Los Angeles Los Angeles World Airport

LA09CV01137GW-O.3.doc

STIPULATED JUDGMENT AGAINST CEED SECURITY, INC. [PROPOSED]

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101 Second Sreet, 24th Floor San Francisco, California 94105 Telephone: [phone]

Robert B. Mobasseri Robert B. Mobasseri Law Offices 445 South Figueroa Street, 27th Floor Los Angeles , California 90071 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail]

Attorney for Defendant Ceed Security, Inc.

(Federal) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. I declare I am employed in the office of a member of the bar of this Court at whose direction the service was made. Executed on January 25, 2010, at San Francisco, California. Patricia Inabnet

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STIPULATED JUDGMENT AGAINST CEED SECURITY, INC. [PROPOSED]

CLYDE & CO US LLP

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LA09CV01137GW-O.3.doc