Trustees of the Western States Income Security Fund et al v. Blanchfield et al

Filing 28

STIPULATION FOR ENTRY OF JUDGMENT AND ORDER, signed by District Judge Lawrence J. O'Neill on 04/5/2013. CASE CLOSED(Martin-Gill, S)

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CATHERINE E. AROSTEGUI, SBN 118756
VISHTASP M. SOROUSHIAN, SBN 278895
BEESON, TAYER & BODINE, APC
483 Ninth Street, Suite 200
Oakland, CA 94607-4051
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]

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Attorneys for Plaintiff
TRUSTEES OF THE WESTERN STATES INCOME SECURITY FUND and GRAPHIC
COMMUNICATIONS INTERNATIONAL UNION EMPLOYER RETIREMENT FUND

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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AT FRESNO

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TRUSTEES OF THE WESTERN STATES
INCOME SECURITY FUND and GRAPHIC
COMMUNICATIONS INTERNATIONAL
UNION EMPLOYER RETIREMENT FUND,

Case No. 1:12-CV-01886-LJO-SKO
STIPULATION FOR ENTRY OF
JUDGMENT AND ORDER

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Plaintiff,
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v.
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JOHN BLANCHFIELD, individually, and CAJON, INC., doing business as Peerless Printers,

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Defendant.

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Plaintiffs TRUSTEES OF THE WESTERN STATES INCOME SECURITY FUND

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(“Western States”) and GRAPHIC COMMUNICATIONS INTERNATIONAL UNION

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EMPLOYER RETIREMENT FUND (“GCIU”) (collectively “Plaintiffs”) and Defendants JOHN

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DAVID BLANCHFIELD, individually, and CA-JON, INC., doing business as Peerless Printers

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(“Defendants”) stipulate and agree that the Court may render judgment in favor of Plaintiffs and

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against Defendants in the amounts set forth by and pursuant to the terms of the respective Settlement

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Agreements and Payments Plans (“Settlement Agreements”) hereby referred to as Exhibits 1 and 2

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and incorporated by reference into this Stipulation for Entry of Judgment and Order (“Stipulation”).

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PROOF OF SERVICE

Case No. 1:12-CV-01886-LJO-SKO

12cv1886.judgment.glg

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IT IS FURTHER STIPULATED and agreed by the parties that if, for any reason, any

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payment under the terms of this Stipulation is not made within ten (10) days of its due date as is

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required by the Settlement Agreements, the Plaintiffs shall, at their option, execute on the entire

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amount of the Judgment, less any payments already made by the Defendants to the Plaintiffs.

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Dated: April 5, 2013

Respectfully Submitted,
BEESON, TAYER & BODINE, APC

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By:

/s/ Vistasp M. Soroushian
CATHERINE E. AROSTEGUI
VISHTASP M. SOROUSHIAN
Attorneys for TRUSTEES OF THE WESTERN
STATES INCOME SECURITY FUND and
GRAPHIC COMMUNICATIONS
INTERNATIONAL UNION EMPLOYER
RETIREMENT FUND

By:

/s/ John Blanchfield
JOHN BLANCHFIELD
In pro per , on behalf of JOHN BLANCHFIELD,
individually, and CA-JON, INC., doing business as
Peerless Printers

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Dated: April 5, 2013

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ORDER AND JUDGMENT

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This Court ENTERS this order and judgment based on the parties’ above stipulation and
DIRECTS the clerk to close this action.

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IT IS SO ORDERED.
Dated:

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April 5, 2013

/s/ Lawrence J. O’Neill
UNITED STATES DISTRICT JUDGE

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DEAC_Signature-END:

66h44d

PROOF OF SERVICE

Case No. 1:12-CV-01886-LJO-SKO

12cv1886.judgment.glg