Southern California Institute of Law v. TCS Education System et al
Filing
79
STATUS REPORT filed by Defendant TCS Education System. (Sarris, Nicholas)
1
2
3
4
5
6
7
8
Jeffrey S. Whittington, Esq./SBN 236028
Email: jwhittington@kbrlaw.com
Nicholas W. Sarris, Esq./SBN 242011
Email: nsarris@kbrlaw.com
Vanessa K. Manolatou, Esq./SBN 266541
Email: vmanolatou@kbrlaw.com
KAUFMAN BORGEEST & RYAN LLP
23975 Park Sorrento, Suite 370
Calabasas, CA 91302
Telephone: (818) 880-0992
Facsimile: (818) 880-0993
Attorneys for Defendant
EDUCATION SYSTEM
TCS
UNITED STATES DISTRICT COURT
9
10
CENTRAL DISTRICT OF CALIFORNIA
11
12
13
14
15
16
17
18
19
20
21
22
)
)
)
)
)
)
Plaintiff,
)
)
vs.
)
)
)
TCS EDUCATION SYSTEM, an
)
Illinois corporation; DAVID J.
)
)
FIGULI, an individual; and
)
GLOBAL EQUITIES, LLC d/b/a
)
HIGHER EDUCATION GROUP, a )
Colorado limited liability company, )
)
)
Defendants.
)
)
SOUTHERN CALIFORNIA
INSTITUTE OF LAW, a California
corporation,
Case No. CV10-8026 JAK (AJWx)
(Assigned to the Hon. John A.
Kronstadt)
JOINT STATUS REPORT
Complaint Filed: October 25, 2010
Discovery Cut-Off: November 30,
2011
Trial Date: March 27, 2012
23
24
TO THE HONORABLE JOHN A. KRONSTADT:
25
I.
THE PARTIES
26
Plaintiff is a for-profit California corporation that operates a law school
27
with campuses in Santa Barbara and Ventura Counties. Defendant TCS is a
28
not-for-profit corporation that affiliates with specialized schools and colleges,
_________________________________________________________________________________________
JOINT STATUS REPORT
1
Printed on Recycled Paper
1704243
1
providing financial support and other resources. Defendant David J. Figuli
2
(“Figuli”) is a Colorado-based attorney who specializes in the education
3
industry. Defendant Global Equities, LLC, which does business as Higher
4
Education Group (“HEG”), provides consulting to post-secondary education
5
institutions.
6
II.
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
CASE STATUS AND SETTLEMENT
On October 3, 2011, the parties appeared for a hearing with respect to
the Motions to Dismiss filed on behalf of each of the defendants.
Such
Motions to Dismiss were granted in part, and denied in part. At the hearing,
the Court directed the parties to return to court on November 28, 2011, to
advise as to the status of settlement efforts between the parties. The Court
further instructed that, if the matter had been settled, no appearance on
November 28, 2011, would be required.
Following the October 3, 2011, hearing on the Motions to Dismiss,
plaintiff filed a Second Amended Complaint on October 18, 2011.
Additionally, and following the taking of several depositions, the parties
participated in private mediation with Philip Meldman, Esq, on November 10,
2011. During mediation, the case settled with respect to all parties.
Inasmuch as the matter has settled, the parties respectfully request that
the November 28, 2011, status conference be taken off calendar.
Within
approximately two weeks, the parties anticipate filing a stipulation of dismissal
with prejudice as to the entire action and lodging a proposed order thereon.
23
24
25
Respectfully submitted,
DATED: November 18, 2011
KAUFMAN BORGEEST & RYAN LLP
26
27
28
By:
/s/ Jeffrey S. Whittington
JEFFREY S. WHITTINGTON, ESQ.
NICHOLAS W. SARRIS, ESQ.
l
_________________________________________________________________________________________
JOINT STATUS REPORT
2
Printed on Recycled Paper
1704243
1
2
3
4
DATED: November 18, 2011
By:
5
6
7
VANESSA K. MANOLATOU, ESQ.
Attorneys for Defendant
TCS EDUCATION SYSTEM
LAW OFFICES OF GEORGE SHOHET
/s/ George A. Shohet
l
GEORGE A. SHOHET, ESQ.
Attorneys for Plaintiff
SOUTHERN CALIFORNIA INSTITUTE
OF LAW
8
9
10
DATED: November 18, 2011
LAW OFFICES OF KREINDLER &
KREINDLER LLP
11
12
By:
13
14
15
/s/ Gretchen M. Nelson
l
GRETCHEN M. NELSON, ESQ.
JACOB MENSCH, ESQ.
Attorneys for Plaintiff
SOUTHERN CALIFORNIA INSTITUTE
OF LAW
16
17
DATED: November 18, 2011
18
19
20
21
22
23
24
By:
LAW
OFFICES
FITZGERALD LLP
OF
STRAZULO
/s/ Maurice J. Fitzgerald
MAURICE J. FITZGERALD, ESQ.
CODY JAFFE, ESQ.
Attorneys for Defendants
DAVID J. FIGULI and GLOBAL
EQUITIES, LLC d/b/a HIGHER
EDUCATION GROUP
l
25
26
27
28
_________________________________________________________________________________________
JOINT STATUS REPORT
3
Printed on Recycled Paper
1704243
PROOF OF SERVICE
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CASE NAME: Southern California Institute of Law v. TCS Education System, et al.
CASE NO.: CV10-8026 PSG
1
2
3
4
5
6
7
8
I declare as follows:
I am employed in the County of Los Angeles, California. I am over the age of 18 years, and
not a party to the within action; my business address is 23975 Park Sorrento, Suite 370, Calabasas,
California 91302. I am readily familiar with my employer’s business practice for collection and
processing of correspondence for mailing with the United States Postal Service. 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 one day after date of deposit for mailing affidavit.
On November 18, 2011, I served a true and correct copy, with all exhibits, of the following
document(s) described as follows:
9
JOINT STATUS REPORT
10
[]
on the interested parties in the within action by placing the above documents in the United
States mail for Express Mail delivery at 23975 Park Sorrento, Suite 370, Calabasas,
California 91302 in a sealed envelope, with Express Mail postage thereon fully prepaid; by
depositing copies of the above documents in a box or other facility regularly maintained by
Federal Express, with delivery fees paid by the sender’s account. (Code of Civil Procedure §
1013(c).) (Overnight Delivery Service)
[]
via CM/ECF (eService)
11
12
13
14
15
on the interested parties in the within action by faxing a true and correct copy of the
above documents to the facsimile number listed below. (Fax Service)
16
17
[]
18
19
on the party or parties named below, by following ordinary business practice, placing a true
copy thereof enclosed in a sealed envelope, for collection and mailing with a United States
Postal Service, where it would be deposited for first class delivery, postage fully prepaid, in
the United States Postal Service, that same day in the ordinary course of business, addressed
as set forth below. (Regular Office Deposit)
20
SEE ATTACHED SERVICE LIST
21
22
23
24
I certify under penalty of perjury under the laws of the State of California that the foregoing
is true and correct and that this declaration was executed on November 18, 2011, at Calabasas,
California.
By:
/s/ Rina Howard
Signature of Declarant
By:
Rina Howard
Name of Declarant
25
26
27
28
_________________________________________________________________________________________
JOINT STATUS REPORT
4
Printed on Recycled Paper
1704243
1
2
3
4
5
6
7
8
9
SERVICE LIST
GEORGE A. SHOHET (SBN 112697)
LAW OFFICES OF GEORGE A. SHOHET, PC
245 Main Street, Suite 310
Venice, CA 90291-5216
Tel.: (310) 452-3176
Fax: (310) 452-2270
Attorneys for Plaintiff SOUTHERN CALIFORNIA INSTITUTE OF LAW
GRETCHEN M. NELSON (SBN 112566)
KREINDLER & KREINDLER LLP
707 Wilshire Blvd., Suite 4100
Los Angeles, CA 90017
Tel.: (213) 622-6469
Fax: (213) 622-6019
Attorneys for Plaintiff SOUTHERN CALIFORNIA INSTITUTE OF LAW
10
11
12
13
14
15
MAURICE J. FITZGERALD
CODY JAFFE
STRAZULO FITZGERALD
3 Embarcadero Center, 8th Floor
San Francisco, CA 94111
Tel.: (415) 394-9500
Fax: (415) 689-1206
Attorneys for Defendants DAVID J. FIGULI and GLOBAL EQUITIES, LLC, DBA HIGHER
EDUCATION GROUP
16
17
18
19
20
21
22
23
24
25
26
27
28
_________________________________________________________________________________________
JOINT STATUS REPORT
5
Printed on Recycled Paper
1704243
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?