Dillett v. Schram et al

Northern District of California, cand-4:2015-cv-01697

STIPULATION AND ORDER re {{25}} Notice (Other) filed by Ann C Dillett, Frederick K. Schram Case Management Conference set for 5/17/2016 01:30 PM. Signed by Magistrate Judge Kandis A. Westmore on 1/14/16.

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1 CHARLES D. COCHRAN, Esq. [State Bar No. 98064] RACHAEL ERICKSON, Esq. [State Bar No. 217445] 2 KORNBLUM, COCHRAN, ERICKSON & HARBISON, LLP 50 Old Courthouse Square, Suite 601 3 Santa Rosa, CA 95404 (707) 544-9006 - Telephone 4 (707) 544-7213 - Facsimile 5 Attorneys for Plaintiff ANN DILLETT 6 7 8 IN THE UNITED STATES DISTRICT COURT 9 FOR THE NORTHERN DISTRICT OF CALIFORNIA 10 11 ANN DILLETT, Individually as the personal Case No.: C 15-01697 KAW representative of FRED C. DILLETT, 12 JOINT NOTICE REGARDING Plaintiff, SETTLEMENT AND REQUEST TO 13 CONTINUE ALL HEARING DATES; v. [PROPOSED] ORDER 14 FRED K. SCHRAM, et al., 15 Defendants. Honorable: Kandis A. Westmore 16 / 17 NOTICE OF SETTLEMENT 18 Plaintiff ANN DILLETT, Individually as the personal representative of FRED C. 19 DILLETT, and Defendant FREDERICK K. SCHRAM, individually and as Trustee of the Up 20 River Family Trust, under Agreement dated 3/15/95, (hereafter the Parties) by and through their 21 counsel of record, hereby notify the Court that the Parties have reached a settlement in the 22 above-entitled matter. The Parties hereby request that the Court vacate all pending due dates and 23 hearings and continue them 120 days to retain jurisdiction over this case until Defendant can 24 fully perform its duties as required under the settlement agreement. It is estimated that Defendant 25 will fully perform its duties on or around April 16th, 2016. Upon Defendant's completion of its 26 duties (as mandated under the settlement agreement) and within two weeks after said 27 completion, Parties will file with this Court a notice of dismissal with prejudice. 28 JOINT NOTICE REGARDING SETTLEMENT AND REQUEST TO CONTINUE ALL HEARING DATES; 1 1 Respectfully Submitted, 2 Dated: January 8, 2016 KORNBLUM, COCHRAN, ERICKSON & HARBISON, LLP 3 4 By: _______/s/__________________________ Charles D. Cochran 5 Attorneys for Plaintiff ANN DILLETT 6 7 8 Dated: January 11, 2016 RAFF LAW, APC 9 10 By: _______/s/_________________________ Daniel S. Raff 11 Counsel for Defendant FREDERICK K SCHRAM, 12 Individually and as Trustee of the Up River Family Trust, under Agreement dated 13 3/15/95 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JOINT NOTICE REGARDING SETTLEMENT AND REQUEST TO CONTINUE ALL HEARING DATES; 2 1 [PROPOSED] ORDER 2 A Joint Notice of Settlement having been filed and good cause appearing therefore, all 3 due dates and hearing in this matter are continued 120 days. This matter shall be scheduled for 4 a further Case Management Conference on ________________________________. May 17, 2016 5 IT IS SO ORDERED. 6 Dated: 1/14/16 ____________________ ___________________________________ 7 Kandis A. Westmore Magistrate Judge 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JOINT NOTICE REGARDING SETTLEMENT AND REQUEST TO CONTINUE ALL HEARING DATES; 3