Gong et al v. Alameda, City of et al

Filing 145

ORDER granting request for an additional 45 days. Signed by Judge Thelton E. Henderson on 01/13/09. (rbe, COURT STAFF) (Filed on 1/14/2009)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Russell A. Robinson, 163937 Law Office of Russell A. Robinson 345 Grove Street, First Floor San Francisco CA 94102 Telephone: 415.255.0462 Facsimile: 415.431.4526 Counsel for Plaintiff HAI-QUI GONG UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA HAI-QUI GONG, Plaintiff, v. RON JONES, No. C-03-5495-TEH CERTIFICATION THAT CONSIDERATION HAS NOT BEEN DELIVERED OVER; REQUEST FOR AN ADDITIONAL 45 DAYS Defendant. _________________________________/ TO THE HONORABLE COURT IN THIS MATTER: PLEASE TAKE NOTICE that Plaintiff and Defendant, through counsel, reported this entire matter had been resolved as to all parties and all causes of action (including settlement as to the claims on appeal of Plaintiff's husband). Because of a late-arising situation (tension and potential conflict) created by the lien of Plaintiff's former counsel, David Beauvais, there was some delay obtaining formal approval of the release and the creation of a mechanism by which all claims, including Mr. Beauvais' lien, would finally be settled. Additionally, Plaintiff, who had been pregnant for most of the past year, delivered her baby daughter a few days ago. Pursuant to the Court's Order of Conditional Dismissal, within 90 days from the date thereof, the agreed consideration for said settlement has not been delivered over. Plaintiff remains hopeful that the requisite consideration will be delivered over, and thus requests an additional 45 --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------CERTIFICATION THAT CONSIDERATION HAS NOT BEEN DELIVERED OVER; REQUEST FOR AN ADDITIONAL 45 DAYS T006CERT Gong v. Jones (No.C-03-5495-TEH) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 days. Counsel for Plaintiff (the undersigned) and David Beauvais have reached an agreement which will be formalized. Counsel for Plaintiff and for Defendant have conferred. Defense counsel has the requisite consideration settlement check awaiting only signatures on the release from Plaintiff, John Peters (the plaintiff's husband), and David Beauvais. DATED: January 9, 2009 UNIT ED S S DISTRICT TE C TA /s/ Russell A. Robinson By: Russell A. Robinson Law Office of Russell A. Robinson, APC Counsel for Plaintiff HAI-QUI GONG RT U O R NIA FO A TE GRAN helton E Judge T D . Hende rson ER 01/13/09 N D IS T IC T R OF C --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------CERTIFICATION THAT CONSIDERATION HAS NOT BEEN DELIVERED OVER; REQUEST FOR AN ADDITIONAL 45 DAYS T006CERT 2 Gong v. Jones (No.C-03-5495-TEH) LI NO RT H

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