RE/MAX, LLC v. Are Group, Inc., et al

Filing 10

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr. on 4/24/2017 ORDERING that the Court STAYS all deadlines in this case for two weeks. (Zignago, K.)

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Ben M. Davidson (State Bar No. 181464)
DAVIDSON LAW GROUP, ALC
11377 West Olympic Boulevard
Los Angeles, California 90064
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Nadya C. Davis (admitted pro hac vice)
HOLLAND & HART, LLP
1800 Broadway, Suite 300
Boulder, Colorado 80302
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Plaintiff
RE/MAX, LLC

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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RE/MAX, LLC, a Delaware limited liability
company,
Plaintiff,
v.

Case No. 2:17-cv-00360-MCE-EFB
STIPULATED REQUEST TO STAY
PROCEEDINGS FOR TWO WEEKS
PENDING SETTLEMENT; ORDER

ARE GROUP, INC., a California corporation,
d/b/a AMEN REAL ESTATE, and JAMES
AMEN, an individual,
Defendants.

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STIPULATED REQUEST TO STAY PROCEEDINGS FOR TWO WEEKS PENDING SETTLEMENT;
ORDER

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Plaintiff, RE/MAX, LLC (“Plaintiff”), and Defendants, ARE Group, Inc., d/b/a Amen Real

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Estate, and James Amen (“Defendants”) (Plaintiff and Defendants collectively, “the Parties”), by

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and through their respective attorneys, hereby submit this Stipulated Request to Stay the Proceedings

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for Two Weeks to allow the Parties time to finalize a settlement. As grounds for this Request, the

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Parties jointly state as follows:

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1)

Plaintiff filed its Complaint on February 17, 2017 [Dkt. 1].

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2)

Defendants were served with the Complaint on February 23, 2017 [Dkts. 6-7].

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3)

Since shortly after service of the Complaint, the Parties have been negotiating the

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terms of a settlement that would resolve all claims at issue in the Complaint.
4)

The Parties recently came to agreement on the keys terms for a full settlement, and

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are now negotiating a formal settlement agreement, which they anticipate being able to finalize

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within two weeks.

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5)

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The Parties respectfully request that the Court stay all deadlines in this case for two

weeks to allow the Parties time to finalize their settlement document.
Dated: April 19, 2017

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Respectfully submitted,

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/s Ben M. Davidson
Ben M. Davidson
DAVIDSON LAW GROUP, ALC
11377 West Olympic Boulevard
Los Angeles, California 90064
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
ATTORNEY FOR PLAINTIFF
RE/MAX, LLC

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/s Erica L. Rosasco (as authorized on April 19, 2017)
Erica L. Rosasco
MCKAGUE ROSASCO PC
2202 Plaza Drive
Rocklin, CA 95756
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
ATTORNEY FOR DEFENDANTS
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STIPULATED REQUEST TO STAY PROCEEDINGS FOR TWO WEEKS PENDING SETTLEMENT;
ORDER

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ORDER
In accordance with the foregoing stipulation, and good cause appearing, the Court hereby
stays all deadlines in this case for two weeks from the date this Order is electronically filed.
IT IS SO ORDERED.
Dated: April 24, 2017

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STIPULATED REQUEST TO STAY PROCEEDINGS FOR TWO WEEKS PENDING SETTLEMENT;
ORDER