Stormwater Systems, Inc. v. Reitmeyer

Filing 85

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 8/25/15 re: 84 : IT IS ORDERED that the parties shall have until Thursday, 8/27/15, to file dispositional documents with this Court. (Meuleman, A)

LAW OFFICES OF LAWRENCE G. TOWNSEND
LAWRENCE G. TOWNSEND (Bar No. 88184)
455 Market Street, 19th Floor
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
[e-mail]
DOWNEY BRAND LLP
ANTHONY L. VIGNOLO (Bar No. 203933)
AVALON J. FITZGERALD (Bar No. 288167)
3425 Brookside Road, Suite A
Stockton, CA 95219-1757
Telephone:
209.473.6450
Facsimile:
209.473.6455
[e-mail]
[e-mail]
Attorneys for Plaintiffs
STORMWATER SYSTEMS, INC., dba SAFE
DRAIN INC., SAFE DRAIN INTERNATIONAL,
INC., and JOHN DEMING
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION

STORMWATER SYSTEMS INC., dba
SAFE DRAIN INC., SAFE DRAIN
INTERNATIONAL INC., and JOHN
DEMING,

Case No.: 2:14-cv-02472-MCE-CKD
STIPULATION EXTENDING TIME TO
FILE DISPOSITIONAL DOCUMENTS

Plaintiffs,
v.
DOUGLAS REITMEYER, MICHAEL
BRASBERGER SR., MICHAEL
BRASBERGER JR., and ASHMB, LLC,
Defendants.

On August 6, 2015, the Court entered the following minute order: “After settlement
negotiations conducted, the parties reached a verbal settlement agreement. The court read the
terms of the settlement for the record. All parties agreed to the terms as stated. Dispositional
documents to be filed within 14 days.” (ECF No. 81.) The parties were therefore required to file
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their dispositional documents on August 20, 2015.
Plaintiffs’ counsel and counsel for Defendants Michael Brasberger Sr., Michael
Brasberger Jr., and ASHMB, LLC, worked diligently to finalize the terms of the dispositional
documents and final settlement agreement by this date. The parties continued to encounter issues
related to the terms of the agreement, and on August 19, 2015, counsel received communications
for the first time from counsel representing third party Benjamin “Buzz” Holmes. Counsel for
Mr. Holmes raised additional issues that have slowed the process for all parties.
Counsel for Plaintiffs and the Brasberger Parties spoke with this Court on Friday, August
21, 2015, and communicated that a further extension until Monday, August 24, 2015, was needed
because of these additional issues.
Plaintiffs and the Brasberger Parties are in agreement as to all terms of the agreement.
However, because Mr. Holmes and Mr. Reitmeyer have not yet communicated that they agree to
the terms of the final settlement agreement, the parties are unable to file dispositional documents
on August 24, 2015.
Accordingly, it is HEREBY STIPULATED by and between Plaintiffs Stormwater
Systems Inc., Safe Drain International, Inc., and John Deming, Defendants Michael Brasberger
Sr., Michael Brasberger Jr., ASHMB, LLC, and Douglas Reitmeyer, that the parties shall have
until Thursday, August 27, 2015, to file dispositional documents with this Court.
SO STIPULATED.

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DATED: August 24, 2015

DOWNEY BRAND LLP

By: /s/ Avalon Johnson Fitzgerald
AVALON JOHNSON FITZGERALD
Attorney for Plaintiffs Stormwater Systems, Inc.,
Safe Drain International, Inc., and John Deming
DATED: August 24, 2015

SESSIONS & ASSOCIATES

By: /s/ Lewis Sessions (as authorized on 8/24/15)
LEWIS SESSIONS
Attorney for Defendants Michael Brasberger Sr.,
Michael Brasberger Jr., and ASHMB, LLC
DATED: August 24, 2015

DOUGLAS REITMEYER

By: /s/ Douglas Reitmeyer (as authorized on 8/24/15)
DOUGLAS REITMEYER
Pro Se

ORDER
For the reasons set forth above, and good cause appearing, the parties shall have until
Thursday, August 27, 2015, to file dispositional documents with this Court.
IT IS SO ORDERED.
Dated: August 25, 2015

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