Joe Hand Promotions Inc v. Edgar Rene Ramirez

Filing 18

ORDER GRANTING STIPULATED JUDGMENT 15 by Judge William D. Keller. The above-entitled action hereby stipulate and respectfully request that judgment in the amount of Twenty Thousand Dollars ($20,000.00) inclusive of attorneys' fees and costs be entered in favor of Plaintiff Joe Hand Promotions, Inc., and against EDGAR RENE RAMIREZ, individually and d/b/a EL CHILITO #2. IT IS SO ORDERED. (lom)

1
2
3
4
5
6

THOMAS P. RILEY, SBN 194706
LAW OFFICES OF THOMAS P. RILEY, P.C.
First Library Square
1114 Fremont Avenue
South Pasadena, CA 91030
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff
Joe Hand Promotions, Inc.

7

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

8
9
10

JOE HAND PROMOTIONS, INC.

11

Plaintiff,

12

ORDER GRANTING
STIPULATED JUDGMENT

vs.

13
14

CASE NO. 2:14-cv-05136-WDK-E

EDGAR RENE RAMIREZ,

15

Defendant.

16
17

TO THIS HONORABLE COURT, ALL PARTIES, AND THEIR

18
19

ATTORNEY/S OF RECORD:

20

By and through their counsel, the Parties to the above-entitled action hereby

21
22

stipulate and respectfully request that judgment in the amount of Twenty Thousand

23

Dollars ($20,000.00) inclusive of attorneys’ fees and costs be entered in favor of

24

Plaintiff Joe Hand Promotions, Inc., and against EDGAR RENE RAMIREZ,

25

individually and d/b/a EL CHILITO #2

26

///

27

///
28

STIPULATED JUDGMENT
CASE NO. 2:14-cv-05136-WDK-E
Page 1

1

The Parties, and each of them, waive any and all rights to seek a stay of

2

enforcement of said judgment and further request that this Honorable Court enter the

3
4

requested and stipulated judgment only in the event of default of the Parties’ settlement
agreement and written notification of same to this Honorable Court by counsel of

5

record.
6
7
8
9
10

IT IS SO ORDERED:

11
12
13

16

________________________________
The Honorable William D. Keller
United States District Court
Central District of California

17

///

14
15

18

Dated:

02/03/2015

///

19

///
20
21

///

22

///

23

///

24

///
25
26

///

27

///

28

PROOF OF SERVICE (SERVICE BY MAIL)
STIPULATED JUDGMENT
CASE NO. 2:14-cv-05136-WDK-E
Page 2

1
2

I declare that:

3

I am employed in the County of Los Angeles, California. I am over the age of

4

eighteen years and not a party to the within cause; my business address is 1114 Fremont

5

Avenue, South Pasadena, California 91030. I am readily familiar with this law firm's

6

practice for collection and processing of correspondence/documents for mail in the

7

ordinary course of business.

8

On December 5, 2014, I served:
[Proposed] ORDER GRANTING STIPULATED JUDGMENT

9
10
11

On all parties referenced by enclosing a true copy thereof in a sealed envelope with

12

postage prepaid and following ordinary business practices, said envelope was addressed

13

to:

14
15

Edgar Rene Ramirez
733 S. Oxnard Blvd.
Oxnard, CA 93030

(Defendant)

16
17

The fully sealed envelope with pre-paid postage was thereafter placed in our law

18

firm’s outbound mail receptacle in order that this particular piece of mail could be taken

19

to the United States Post Office in South Pasadena, California later this day by myself (or

20

by another administrative assistant duly employed by our law firm).

21

I declare under the penalty of perjury pursuant to the laws of the United States that

22

the foregoing is true and correct and that this declaration was executed on December 5,

23

2014, at South Pasadena, California.

24
25

Dated: December 5, 2014
VANESSA VENTURA

26
27
28

STIPULATED JUDGMENT
CASE NO. 2:14-cv-05136-WDK-E
Page 3