Yates v. Sweet Potato Enterprise, Inc. et al

Filing 54

STIPULATION AND ORDER re 44 STIPULATION WITH PROPOSED ORDER AND JOINT CERTIFICATION OF COUNSELS' MEET AND CONFER RE: MOTIONS IN LIMINE filed by Sweet Potato Enterprise, Inc., Helen L. Ng, Craig Yates, Kuan L. Ng. Signed by Judge ARMSTRONG on 3/13/13. (lrc, COURT STAFF) (Filed on 3/13/2013)

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THOMAS E. FRANKOVICH (State Bar No. 074414)
GEORGE S. KHOURY (State Bar No. 269738)
THOMAS E. FRANKOVICH,
A Professional Law Corporation
4328 Redwood Hwy, Suite 300
San Rafael, CA 94109
Telephone: [phone]
Facsimile:
415/444-5805

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Attorneys for Plaintiff
CRAIG YATES, an individual

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Tyler M. Paetkau (SBN 146305)
James H. Harnett (SBN 84587)
Charles J. Smith (SBN 72700)
HARTNETT, SMITH & PAETKAU
777 Marshall Street
Redwood City, CA 94063
Telephone: [phone]
Facsimile: [phone]

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Attorney for Defendants
SWEET POTATO ENTERPRISE, INC.,
a California Corporation dba POPEYES STORE # 2794;
and KUAN L. NG and HELEN L. NG, Trustees,
of THE KUAN L. NG AND HELEN L. NG
REVOCABLE TRUST OF 1993

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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CRAIG YATES, an individual;

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Plaintiff,
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v.
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SWEET POTATO ENTERPRISE, INC., a
California Corporation dba POPEYES STORE )
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# 2794; and KUAN L. NG and HELEN L. NG,)
Trustees, of THE KUAN L. NG AND HELEN )
)
L. NG REVOCABLE TRUST OF 1993,
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Defendants.
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CERTIFICATION OF MEET AND CONFER AND STIPULATION

CASE NO. C 11-01950 SBA
JOINT CERTFICATION OF COUNSELS’
MEET AND CONFER RE: MOTIONS IN
LIMINE AND STIPULATION TO
EXCLUDE MENTION OF, OR
EVIDENCE RELATING TO, CERTAIN
ISSUES AND ORDER THEREON

CASE NO. CV-11-01950 SBA

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The parties to the above-captioned action, through their respective counsels, jointly
submit this Certification that Counsel for plaintiff and defendants have met and conferred as to

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each issue raised by the Motions In Limine presented to this Court, pursuant to Judge
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Armstrong’s September 21, 2012 Standing Order, and the February 14, 2013 Order Striking

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Plaintiff’s Motions In Limine.

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On February 15, 2013, attorney George S. Khoury, for plaintiff, and attorneys Tyler

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Paetkau and Olga Savage, for defendants, did meet and confer as to each and every issue raised
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in the respective motions in limine. Counsel discussed each issue in good faith, and attempted to
resolve each issue informally.

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In discussing the issues, counsel were able to agree to, and hereby stipulate that:

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1.)

Defendants will not mention, or seek to introduce into evidence, information that

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relates to plaintiff CRAIG YATES receipt of disability benefits and social security.
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2.)

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to how plaintiff CRAIG YATES became disabled.

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Plaintiff will not mention, or seek to introduce into evidence, information relating

Respectfully submitted,
Dated:

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THOMAS E. FRANKOVICH,
A PROFESSIONAL LAW CORPORATION

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By:

_/s/ George S. Khoury____________
Thomas E. Frankovich
George S. Khoury
Attorneys for Plaintiff CRAIG YATES

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CERTIFICATION OF MEET AND CONFER AND STIPULATION

CASE NO. CV-11-01950 SBA

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Dated:

HARTNETT, SMITH & PAETKAU

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By: ____/s/ Tyler Paetkau _______________
Tyler Paetkau
Olga Savage
Attorneys for Defendants SWEET POTATO
ENTERPRISE, INC., a California Corporation dba
POPEYES STORE # 2794; and KUAN L. NG and
HELEN L. NG, Trustees, of THE KUAN L. NG
AND HELEN L. NG REVOCABLE TRUST OF
1993

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ORDER
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IT IS SO ORDERED that pursuant to the stipulation of the parties: 1.) defendants shall

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not mention, or seek to introduce into evidence, at trial, information that relates to plaintiff

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CRAIG YATES receipt of disability benefits and social security; and 2.) plaintiff shall not

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mention, or seek to introduce into evidence, at trial, information relating to how plaintiff CRAIG

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YATES became disabled.
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Dated: 3/13/13
______________________________
Honorable Judge Saundra Brown Armstrong
United States District Court, Northern District
of California

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CERTIFICATION OF MEET AND CONFER AND STIPULATION

CASE NO. CV-11-01950 SBA

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