Confi-Chek, Inc. v. Rahman et al

Filing 18

STIPULATION and ORDER signed by District Judge John A. Mendez on 10/31/18. The parties are agreeable to the Court's maintaining jurisdiction over this action until 12/14/18, or such other time as the Court deems appropriate, so that the Court can take any necessary measures to enforce the terms of the settlement agreement, and its amendment, if Defendants fail to honor their obligations thereunder. (Mena-Sanchez, L)

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Josh H. Escovedo, State Bar No. 284506
Zachary S. Thompson, State Bar No. 317110

WEINTRAUB TOBIN CHEDIAK COLEMAN GRODIN
Law Corporation

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400 Capitol Mall, 11th Floor
Sacramento, California 95814
Telephone: [phone]
Facsimile:
916.446.1611
Email: [e-mail]

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Attorneys for Plaintiff and Counterdefendant Confi-Chek, Inc.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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CONFI-CHEK, INC., a California corporation,

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law corporation

weintraub tobin chediak coleman grodin

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Plaintiff,
vs.
ASHFAQ RAHMAN, an individual;
LOCALBLOX, INC., a Washington
corporation; and DOES 1 through 100,
inclusive,
Defendants.

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AND RELATED COUNTERCLAIM.

Case No. 2:17-cv-02135-JAM-EFB
STIPULATION REQUESTING THE COURT TO
MAINTAIN JURISDICTION THROUGH
DECEMBER 14, 2018

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On March 30, 2018, the parties jointly submitted a notice of settlement. ECF No. 15. In

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that document, the parties noted that the resolution required Defendants to perform certain

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obligations that could not be completed until September 15, 2018, and as such, the parties

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requested that the Court maintain jurisdiction until September 30, 2018, so the Court could

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enforce the settlement agreement or enter the agreed-upon stipulated judgment if

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Defendants failed to honor their obligations. Accordingly, the Court entered an order

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maintaining jurisdiction but requiring the parties to file settlement/dismissal documents no

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later than September 28, 2018. ECF No. 16.
{2507930.DOCX;}

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Stipulation Requesting the Court to Maintain
Jurisdiction Through December 14, 2018

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The parties amended the settlement agreement to allow Defendants until November

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15, 2018 to satisfy their obligations thereunder. Accordingly, the parties request that the

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Court maintain jurisdiction for a reasonable period of time following that date to enable the

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Court to enforce the settlement agreement or enter the stipulated judgment if Defendants

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fail to honor the terms of the amendment to the settlement agreement. To that end, the

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parties jointly request that the Court maintain jurisdiction until December 14, 2018.
Accordingly, the parties hereby stipulate as follows:

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The parties are agreeable to the Court’s maintaining jurisdiction over this action until

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December 14, 2018, or such other time as the Court deems appropriate, so that the Court

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can take any necessary measures to enforce the terms of the settlement agreement, and its

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amendment, if Defendants fail to honor their obligations thereunder.

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Dated: October 30, 2018

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law corporation

weintraub tobin chediak coleman grodin

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WEINTRAUB TOBIN CHEDIAK COLEMAN GRODIN
Law Corporation

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By:

/s/ Josh H. Escovedo
Josh H. Escovedo
California State Bar No. 284506
Attorneys for Plaintiff and Counterdefendant
Confi-Chek, Inc.

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Respectfully submitted,

Dated: October 30, 2018

Respectfully submitted,

KARR TUTTLE CAMPBELL

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A Professional Corporation

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By:

/s/ J. Dino Vasquez
J. Dino Vasquez
California State Bar No. 146725
Attorneys for Defendants and Counterclaimants
Ashfaq Rahman and LocalBlox, Inc.

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{2507930.DOCX;}

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Stipulation Requesting the Court to Maintain
Jurisdiction Through December 14, 2018

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ORDER
IT IS SO ADJUDGED AND ORDERED.

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Dated: 10/31/2018

/s/ John A. Mendez_______________
The Honorable John A. Mendez
United States District Court Judge

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law corporation

weintraub tobin chediak coleman grodin

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{2507930.DOCX;}

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Stipulation Requesting the Court to Maintain
Jurisdiction Through December 14, 2018