Cartagz, Inc. v. Sanders, et al.

Filing 70

STIPULATION and ORDER signed by Magistrate Judge Gregory G. Hollows on 9/30/2016 that the deadline to file the stipulated order concisely setting forth all aspects of the settlement agreement be CONTINUED to 10/10/2016 from 9/26/2016. (Jackson, T)

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LECLAIRRYAN, LLP
Robert S. McWhorter (CA 226186)
Kevin T. Collins (CA 185427)
Jacqueline N. Vu (CA 287011)
400 Capitol Mall, Suite 1500
Sacramento, CA 95814
Telephone: [phone]
Facsimile: 916.246.1155
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants and Counter-Claimants,
GREGORY SANDERS, CATHY SANDERS,
erroneously sued as KATHY SANDERS,
and CAR REGISTRATION, INC. erroneously
sued as EZTAGS, INC.
MILLSTONE PETERSON & WATTS, LLP
Glenn W. Peterson (SBN 126173)
2267 Lava Ridge Court, Suite 210
Roseville, CA 95661
Telephone: [phone]
Facsimile: [phone]
Attorneys for Counter-Defendants
Cartagz, Inc., a California corporation and
Troy Greeson and Chrizelda Machuca

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO DIVISION

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CARTAGZ, INC., a California corporation,
Plaintiff,

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v.
GREGORY SANDERS; KATHY SANDERS;
CALIFORNIA REGISTRATION, INC., a
California corporation (formerly EZTAG);
CONTINUUM DATA PRODUCTS, a
California Corporation, DAWN COOKS and
RICHARD COOKS

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Case No.: 2:15-cv-01918-MCE-GGH
STIPULATION AND ORDER TO
EXTEND TIME FOR THE PARTIES TO
FILE A STIPULATED ORDER
CONCISELY SETTING FORTH ALL
ASPECTS OF THE SETTLEMENT
AGREEMENT
(Sacramento County Superior Court
Case No. 34-2015-00182997)

Defendants.
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STIPULATION AND [PROPOSED] ORDER
TO EXTEND TIME FOR THE PARTIES TO FILE THE SETTLEMENT AGREEMENT

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GREGORY SANDERS; CATHY SANDERS;
and CAR REGISTRAITON, INC., a
California corporation
Counter-Claimants,

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vs.
CARTAGZ, INC., a California corporation;
TROY GREESON; CHRIZELDA
MACHUCA; and Roes 1 to 25, inclusive
Counter-Defendants.

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STIPULATION AND [PROPOSED] ORDER
TO EXTEND TIME FOR THE PARTIES TO FILE THE SETTLEMENT AGREEMENT

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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 and between defendants and counter-claimants Car Registration, Inc., Gregory Sanders and
Cathy Sanders (collectively “Defendants”), on the one hand, and plaintiff and counter-defendants
Cartagz, Inc., Troy Greeson and Chrizelda Machuca (collectively “Plaintiffs”), on the other hand,
(collectively, the “Parties”) by and through their respective counsel of record with reference to
following facts:

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WHEREAS, on August 11, 2016, the Parties met in a 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 agreement to file by August 31, 2016 a stipulated order concisely setting forth all aspects of
the 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;

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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;

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WHEREAS, counsel for Plaintiffs, Matthew Brady, recently had surgery and needed
additional time to confer with defense counsel on the drafting of the settlement papers;

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WHEARAS, the Parties have successfully resolved many issues relating to the drafting of
the settlement papers, but are in need of additional time to negotiate the last few remaining issues
relating to the language of the final settlement agreement;

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WHEREAS, the Parties are hopeful and fully anticipate that they will agree upon the
language of the final settlement agreement as only a very few issues remain; and

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WHEREAS, the Parties mutually agree that the Court may enter an order upon this
stipulation.
///
///

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STIPULATION AND [PROPOSED] ORDER
TO EXTEND TIME FOR THE PARTIES TO FILE THE SETTLEMENT AGREEMENT

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NOW THEREFORE, it is hereby stipulated by and between the Parties hereto, through
their respective counsel, that the deadline to file the stipulated order concisely setting forth all
aspects of the settlement agreement be continued October 10, 2016 from September 26, 2016.
Stipulated and agreed to by:
Dated: September 26, 2016

LeClairRyan LLP

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By:

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/s/ Kevin T. Collins
Kevin T. Collins

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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Dated: September 26, 2016

MILLSTONE PETERSON & WATTS, LLP

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By:

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Attorneys for Plaintiff and Counter-Defendants
CARTAGZ, INC., TROY GREESON and
GRIZELDA MACHUCA

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/s/ Glenn W. Peterson
Glenn W. Peterson

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Dated: September 26, 2016

LAW OFFICES OF MATTHEW V. BRADY

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By:

/s/ Matthew V. Brady
Matthew V. Brady

Attorneys for Plaintiff and Counter-Defendants
CARTAGZ, INC., TROY GREESON and
GRIZELDA MACHUCA

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STIPULATION AND [PROPOSED] ORDER
TO EXTEND TIME FOR THE PARTIES TO FILE THE SETTLEMENT AGREEMENT

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ORDER
Based on the above stipulation of the parties and good cause appearing, the parties will
file their Proposed Settlement Order no later than October 10, 2011.
Should the Proposed Settlement Order not be filed on the above date, the parties shall contact the
courtroom clerk of the undersigned and schedule a hearing regarding dispute resolution for the
next available date on the calendar of the undersigned.
IT IS SO ORDERED.

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Dated: September 30, 2016
/s/ Gregory G. Hollows
GREGORY G. HOLLOWS
United States Magistrate Judge

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STIPULATION AND [PROPOSED] ORDER
TO EXTEND TIME FOR THE PARTIES TO FILE THE SETTLEMENT AGREEMENT