Trillanes-Gam v. Target Corporation

Filing 12

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 3/6/18, ORDERING that the amount of damages claimed in this matter is and will remain under the statutory minimum of $75,000.00 for the duration of this lawsuit. This matter is REMANDED back to the Superior Court of California, County of Sacramento. Certified copy of this Order sent to the State Court. CASE CLOSED (Kastilahn, A)

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Michael R. Mordaunt, Esq., Bar No. 66911
Lori A. Reihl, Esq., Bar No. 246395
RIGGIO MORDAUNT & KELLY
A Professional Law Corporation
Mailing Address: P.O. Box 7608
Stockton, CA 95267
Physical Address: 2509 W. March Lane, Suite 200
Stockton, CA 95207
Telephone: [phone]
Attorneys for Defendant
TARGET CORPORATION

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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EVELYN TRILLANES-GAM
Plaintiff(s),

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vs.

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TARGET CORPORATION and DOES
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Defendant(s).
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It is further stipulated that plaintiff, EVELYN TRILLANES-GAM, agrees to a covenant not
to execute on any judgment in this matter exceeding $75,000.00.
It is further stipulated that plaintiff EVELYN TRILLANES-GAM waives any right to void
this stipulation on the basis of any newly-discovered or unknown facts.

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STIPULATION THAT DAMAGES IN THIS
ACTION WILL NOT EXCEED THE
AMOUNT OF $75,000.00 AND TO REMAND
THE CASE TO THE SUPERIOR COURT OF
CALIFORNIA, COUNTY OF SACRAMENTO

that the total amount of damages claimed in this matter are less than $75,000.00.

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Case No. 2:17-CV-02377-KJM-AC

IT IS HEREBY STIPULATED by and between the parties through their counsel of record

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On the basis of this stipulation, and the representations made by plaintiff’s attorneys that the
value of this matter is under $75,000.00, the parties stipulate and agree that this case shall be

24 remanded the Superior Court of California, County of Sacramento.
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The parties further stipulate that each side will bear their own fees and costs and that there

26 shall be no award of fees or costs as part of this remand.
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Riggio Mordaunt & Kelly
P.O. Box 7608
Stockton, CA 95267
[phone]

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STIPULATION THAT DAMAGES IN THIS ACTION WILL NOT EXCEED THE AMOUNT OF $75,000.00 AND
TO REMAND THE CASE TO THE SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO

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Both plaintiff and defendant request that the Court remand the case to the Superior Court of
California, County of Sacramento.
IT IS SO STIPULATED:

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Dated: February 21, 2018

RIGGIO MORDAUNT & KELLY

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By:
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/s/ Lori A. Reihl for
Michael R. Mordaunt, Esq.
Lori A. Reihl, Esq.
Attorneys for Defendant
TARGET CORPORATION

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Dated: February 21, 2018
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RUCKA, O’BOYLE, LOMBARDO &
McKENNA

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By:
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/s/ Neil Berman
Neil Berman, Esq.
Attorneys for Plaintiff
EVELYN TRILLANES-GAM

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ORDER

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Based on the stipulation of all parties that the amount of damages claimed in this matter is
and will remain under the statutory minimum of $75,000.00 for the duration of this lawsuit,
IT IS HEREBY ORDERED that this matter be remanded back to the Superior Court of

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California, County of Sacramento.

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DATED: March 6, 2018.

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UNITED STATES DISTRICT JUDGE

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Riggio Mordaunt & Kelly
P.O. Box 7608
Stockton, CA 95267
[phone]

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STIPULATION THAT DAMAGES IN THIS ACTION WILL NOT EXCEED THE AMOUNT OF $75,000.00 AND
TO REMAND THE CASE TO THE SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO