Torres v. Carescope LLC et al

Filing 93

STIPULATION AND ORDER signed by Magistrate Judge Carolyn K. Delaney on 6/27/2022 AMENDING Dismissal date to comply with settlement agreement and ORDERING that Plaintiff's deadline to submit a Request of Dismissal of the Litigation with prejudice is SET for 5/25/2024 contingent on Defendant's compliance with the payment schedule. The Clerk of Court is directed to administratively close this case. CASE CLOSED. (Mena-Sanchez, L)

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STAN S. MALLISON (SBN 184191)
[e-mail]
HECTOR R. MARTINEZ (SBN 206336)
[e-mail]
HEATHER M. HAMILTON (SBN 332545)
[e-mail]
MALLISON & MARTINEZ
1939 Harrison Street, Suite 730
Oakland, California 94612-3547
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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ANTONETT TORRES,

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Plaintiff,
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v.
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CARESCOPE, LLC dba VOICE FOR )
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SENIORS,
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Defendant,
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Case No. 2:15-CV-00198-TLN-CKD
JOINT STIPULATION AND ORDER
TO AMEND DISMISSAL DATE TO
COMPLY WITH SETTLEMENT
AGREEMENT
Before Magistrate Judge Caroline K.
Delaney
Proposed Dismissal Date: May 25, 2024

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JOINT STIPULATION AND PROPOSED ORDER TO AMEND
DISMISSAL DATE TO COMPLY WITH SETTLEMENT AGREEMENT

STIPULATION

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Plaintiff Antonett Torres (“Plaintiff”), by and through her counsel, the law

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firm of Mallison & Martinez, and Defendant CARESCOPE, LLC dba VOICE

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FOR SENIORS (“Defendant”), by and through its counsel, Levangie Law Group,

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hereby stipulate and agree to amend Plaintiff dismissal date to comply with the

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settlement agreement as a matter of course.

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WHEREAS, on May 20, 2022, the Parties finalized a Settlement Agreement
and Release of All Claims;
WHEREAS, the Parties agreed that Defendant shall make a Settlement
Payment in quarterly installments after an initial payment of $25,000;
WHEREAS, the Parties determined that Defendant shall make its final
quarterly installment on May 15, 2024;

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WHEREAS, Plaintiff agreed to dismiss the litigation in its entirety with

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prejudice within 10 business days of the receipt of the final payment by Plaintiff’s

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Counsel.

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NOW THEREFORE, the Parties STIPULATE as follows and respectfully
request the Court amend the dismissal date as follows:

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• Plaintiff’s deadline to submit a Request of Dismissal of the Litigation

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with prejudice is set on May 25, 2024 contingent on Defendant’s

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compliance with the payment schedule.

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IT IS SO STIPULATED.
DATED: June 22, 2022

MALLISON & MARTINEZ
By: ______________________________
Stan S. Mallison
Hector R. Martinez
Heather M. Hamilton
Attorneys for Antonett Torres
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JOINT STIPULATION AND PROPOSED ORDER TO AMEND
DISMISSAL DATE TO COMPLY WITH SETTLEMENT AGREEMENT

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DATED: June 22, 2022

LEVANGIE LAW GROUP
By: _____/s/_______________________
Michael J. Levangie
Sharon B. Futerman
Attorneys for Defendant
CARESCOPE, LLC dba VOICE FOR
SENIORS

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JOINT STIPULATION AND PROPOSED ORDER TO AMEND
DISMISSAL DATE TO COMPLY WITH SETTLEMENT AGREEMENT

ORDER

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The Court, having fully considered the settlement agreement, HEREBY
ORDERS that

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1. Plaintiff’s deadline to submit a Request of Dismissal of the

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Litigation with prejudice be set on May 25, 2024 contingent on

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Defendant’s compliance with the payment schedule.

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2. The Clerk of Court is directed to administratively close this case.
IT IS SO ORDERED.
Dated: June 27, 2022
_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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JOINT STIPULATION AND PROPOSED ORDER TO AMEND
DISMISSAL DATE TO COMPLY WITH SETTLEMENT AGREEMENT