Cartagz, Inc. v. Sanders, et al.
Filing
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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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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
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Attorneys for Counter-Defendants
Cartagz, Inc., a California corporation and
Troy Greeson and Chrizelda Machuca
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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.
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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.
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) 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),
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CONTINUUM DATA PRODUCTS, a
California Corporation, DAWN COOKS and )
)
RICHARD COOKS
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Defendants.
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STIPULATION AND PROPOSED ORDER
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GREGORY SANDERS; CATHY SANDERS; )
and CAR REGISTRATION, INC., a California )
)
corporation
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Counter-Claimants,
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vs.
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CARTAGZ, INC., a California corporation;
TROY GREESON; CHRIZELDA MACHUCA; )
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and Roes 1 to 25, inclusive
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Counter-Defendants.
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STIPULATION
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This stipulation to extend the time to finalize the settlement of this action is entered into by
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and between defendants and counter defendants Car Registration, Inc., Gregory Sanders and Cathy
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Sanders (collectively “Defendants”), on the one hand, and plaintiff and counter-defendants Cartagz,
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Inc., Troy Greeson and Chrizelda Machuca (collectively “Plaintiffs”), on the other hand, by and
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through their respective counsel of record with reference to following facts:
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WHEREAS, on August 11, 2016, the parties met in settlement conference and resolved to
settle the above referenced litigation prior to trial;
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WHEREAS, the principal terms of the settlement were set forth on the record, including an
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agreement to file by August 31, 2016 a stipulated order concisely setting forth all aspects of the
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settlement agreement;
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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;
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WHEREAS, Plaintiffs and Defendants remain hopeful and fully anticipate that the parties will
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agree upon the language of the final settlement agreement, but are in need of more time to accomplish
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that; at minimum, the parties believe that additional time will reduce the number and the extent of
-2STIPULATION AND PROPOSED ORDER
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issues that might be submitted for court resolution;
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WHEREAS, the parties mutually agree that the Court may enter an order upon this stipulation.
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NOW THEREFORE, it is hereby stipulated by and between the parties hereto, through their
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respective counsel, that the deadline to file the stipulated order concisely setting forth all aspects of
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the settlement agreement be continued an additional ten days to September 26, 2016 from September
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16, 2016.
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Stipulated and agreed to by:
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DATED: September 20, 2016
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LAW OFFICES OF MATTHEW V. BRADY
and
MILLSTONE, PETERSON & WATTS, LLP
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By:
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Attorneys for Plaintiff/Counter-Defendant
Cartagz, Inc., a California corporation
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/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.
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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
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-3STIPULATION AND PROPOSED ORDER
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ORDER
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Based on the above stipulation of the parties and good cause appearing,
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IT IS SO ORDERED.
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Dated: September 20, 2016
/s/ Gregory G. Hollows
UNITED STATES MAGISTRATE JUDGE
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-4STIPULATION AND PROPOSED ORDER
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