Anthoine v. North Central Counties Consortium, et al.,

Filing 85

STIPULATION and ORDER signed by Judge John A. Mendez on 4/11/11 ORDERING that the deadline for full implementation of the settlement and filing a Stipulation for Dismissal is EXTENDED from 4/8/11 to 4/30/2011. (Mena-Sanchez, L)

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MICHAEL E. ADAMS (SBN: 47278)
LAW OFFICES OF MICHAEL E. ADAMS
702 Marshall Street, Suite 300
Redwood City, CA 94063
Telephone: [phone]
Fax:
[phone]

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Attorney for Plaintiff NELSON ANTHOINE
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Case No. 2:06-CV-01169-DFL-KJM
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NELSON H. ANTHOINE,

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Plaintiff,
STIPULATION TO EXTEND
TIME FOR COMPLETION OF
SETTLEMENT; SUPPORTING
DECLARATION; ORDER

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v.

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NORTH CENTRAL COUNTIES
CONSORTIUM, LORI BROWN, and
CINDY NEWTON,

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Defendants.
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___________________________________
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The parties hereto, by and through their respective undersigned counsel, hereby

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stipulate, subject to court approval, to extend from April 8, 2011 to April 30, 2011 the

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deadline for the parties to fully implement their settlement and file a stipulated dismissal.

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The reason for this stipulation, as further detailed in the supporting declaration below, is

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that the settlement agreement is not yet fully signed and implemented, and the parties

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anticipate that the remaining signatures and implementation will be completed within

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approximately three weeks.

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L AW O FFICES O F
M ICHAEL E. A DAMS
702 M ARSHALL S T ., #300
R EDW OOD C ITY C A 94063
[phone]

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Stipulation to Extend Time for Completion of Settlement; Supporting Declaration; [Proposed] Order

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DATED: March 9, 2011

DATED: March 9, 2011

/s/ Michael E. Adams
__________________________
MICHAEL E. ADAMS
Attorney for Plaintiff
NELSON H. ANTHOINE

/s/ Mark P. Grajski
___________________________
MARK P. GRAJSKI
Attorney for Defendants
NORTH CENTRAL COUNTIES
CONSORTIUM, LORI BROWN,
and CINDY NEWTON

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SUPPORTING DECLARATION

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I, MICHAEL E. ADAMS, hereby declare:

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1. I am the attorney of record herein for Plaintiff Nelson Anthoine.

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2. The written settlement agreement between the parties has thus far been signed

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by Plaintiff and on behalf of Defendant North Central Counties Consortium (“NCCC”),

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and I have received two of the three settlement checks that NCCC has undertaken to

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issue. Opposing counsel, Mark Grajski, assures me that, by next week, I will be receiving

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the remaining settlement check, as well as copies of the settlement agreement signed by

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Defendants Lori Brown and Cindy Newton. I anticipate that, once the settlement checks

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are deposited, it may take 7-10 days for them to clear. Once the checks all clear, I will be

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in a position to join with Mr. Grajski in filing a stipulation for dismissal of this entire

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case.

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I declare under penalty of perjury that the foregoing is true and correct. Signed
this 7th day of April, 2011 in Redwood City, CA.

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/s/ Michael E. Adams
___________________________
MICHAEL E. ADAMS

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L AW O FFICES O F
M ICHAEL E. A DAMS
702 M ARSHALL S T ., #300
R EDW OOD C ITY C A 94063
[phone]

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Stipulation to Extend Time for Completion of Settlement; Supporting Declaration; [Proposed] Order

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ORDER

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The parties so stipulating, and good cause appearing,

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IT IS HEREBY ORDERED that the deadline for full implementation of the settlement

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and filing a stipulation for dismissal is extended from April 8 to April 30, 2011.

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Dated: April 11, 2011

/s/ John A. Mendez
HON. JOHN A. MENDEZ
U.S. DISTRICT COURT JUDGE

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L AW O FFICES O F
M ICHAEL E. A DAMS
702 M ARSHALL S T ., #300
R EDW OOD C ITY C A 94063
[phone]

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Stipulation to Extend Time for Completion of Settlement; Supporting Declaration; [Proposed] Order