Cartagz, Inc. v. Sanders, et al.

Filing 67

STIPULATION and ORDER signed by Magistrate Judge Gregory G. Hollows on 09/20/16 ORDERING that the deadline to file the stipulated order concisely setting forth all aspects of the settlement agreement is CONTINTUED to 09/26/16. (Benson, A)

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1 2 3 MILLSTONE PETERSON & WATTS, LLP Glenn W. Peterson (SBN 126173) 2267 Lava Ridge Court, Suite 210 Roseville, CA 95661 Telephone: (916) 780-8222; Fax No: (916) 780-8775 4 5 Attorneys for Counter-Defendants Cartagz, Inc., a California corporation and Troy Greeson and Chrizelda Machuca 6 7 8 9 10 11 12 13 14 15 LECLAIRRYAN Robert S. McWhorter (CA 226186) Kevin T. Collins (CA 185427) Jacqueline N. Vu (CA 287011) 980 9th Street, 16th Floor Sacramento, CA 95814 Telephone: 916.449.9690 Facsimile: 916.449.9694 robert.mcwhorter@leclairryan.com kevin.collins@leclairryan.com Attorneys for Defendants GREGORY SANDERS, CATHY SANDERS, erroneously sued as KATHY SANDERS, and CAR REGISTRATION, INC. erroneously sued as EZTAGS, INC. 16 17 18 19 20 21 22 23 24 25 26 27 28 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA ) Case No. 2:15-cv-01918-MCE-GGH CARTAGZ, INC., a California corporation, ) ) STIPULATION AND ORDER TO Plaintiff, ) EXTEND TIME FOR THE PARTIES vs. ) ) TO FILE A STIPULATED ORDER GREGORY SANDERS; CATHY SANDERS, ) CONCISELY SETTING FORTH ALL ) ASPECTS OF THE SETTLEMENT CALIFORNIA REGISTRATION, INC., a ) AGREEMENT California corporation (formerly EZTAG), ) CONTINUUM DATA PRODUCTS, a California Corporation, DAWN COOKS and ) ) RICHARD COOKS ) ) Defendants. ) ) ) ) ) ) STIPULATION AND PROPOSED ORDER __ 1 2 3 4 5 6 7 GREGORY SANDERS; CATHY SANDERS; ) and CAR REGISTRATION, INC., a California ) ) corporation ) ) Counter-Claimants, ) vs. ) ) ) CARTAGZ, INC., a California corporation; TROY GREESON; CHRIZELDA MACHUCA; ) ) and Roes 1 to 25, inclusive ) ) Counter-Defendants. ) 8 STIPULATION 9 10 This stipulation to extend the time to finalize the settlement of this action is entered into by 11 and between defendants and counter defendants Car Registration, Inc., Gregory Sanders and Cathy 12 Sanders (collectively “Defendants”), on the one hand, and plaintiff and counter-defendants Cartagz, 13 Inc., Troy Greeson and Chrizelda Machuca (collectively “Plaintiffs”), on the other hand, by and 14 through their respective counsel of record with reference to following facts: 15 16 WHEREAS, on August 11, 2016, the parties met in settlement conference and resolved to settle the above referenced litigation prior to trial; 17 WHEREAS, the principal terms of the settlement were set forth on the record, including an 18 agreement to file by August 31, 2016 a stipulated order concisely setting forth all aspects of the 19 settlement agreement; 20 21 22 23 24 25 WHEREAS, counsel for Defendants took the “laboring oar” in preparing the first draft of the settlement agreement and timely provided it to counsel for Plaintiffs, on August 19, 2016; WHEREAS, since August 19, 2016, certain issues and disagreements have arisen that have prevented the parties from completing the negotiation and drafting of the settlement papers; WHEREAS, counsel for Plaintiffs, Matthew Brady, recently had surgery and will need additional time to confer with defense counsel on the drafting of the settlement papers; 26 WHEREAS, Plaintiffs and Defendants remain hopeful and fully anticipate that the parties will 27 agree upon the language of the final settlement agreement, but are in need of more time to accomplish 28 that; at minimum, the parties believe that additional time will reduce the number and the extent of -2STIPULATION AND PROPOSED ORDER 1 issues that might be submitted for court resolution; 2 WHEREAS, the parties mutually agree that the Court may enter an order upon this stipulation. 3 NOW THEREFORE, it is hereby stipulated by and between the parties hereto, through their 4 respective counsel, that the deadline to file the stipulated order concisely setting forth all aspects of 5 the settlement agreement be continued an additional ten days to September 26, 2016 from September 6 16, 2016. 7 Stipulated and agreed to by: 8 DATED: September 20, 2016 9 10 LAW OFFICES OF MATTHEW V. BRADY and MILLSTONE, PETERSON & WATTS, LLP 11 By: 12 13 Attorneys for Plaintiff/Counter-Defendant Cartagz, Inc., a California corporation 14 15 16 17 18 19 /s/ Glenn W. Peterson GLENN W. PETERSON DATED: September 20, 2016 LECLAIRRYAN LLP By: /s/ Kevin T. Collins KEVIN T. COLLINS (AS AUTHORIZED ON 9/15/16) Attorneys for Defendants Gregory Sanders, Cathy Sanders, erroneously sued as Kathy Sanders, and Car Registration, Inc. erroneously sued as EZTAGS, Inc. 20 21 I hereby attest that I have on file all holograph signatures for any signatures indicated by a "conformed" signature (/s/) within this e-filed document. MILLSTONE PETERSON & WATTS, LLP /s/ Glenn W. Peterson 22 23 24 25 26 27 28 -3STIPULATION AND PROPOSED ORDER 1 ORDER 2 Based on the above stipulation of the parties and good cause appearing, 3 IT IS SO ORDERED. 4 5 6 Dated: September 20, 2016 /s/ Gregory G. Hollows UNITED STATES MAGISTRATE JUDGE 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -4STIPULATION AND PROPOSED ORDER

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