Free Stipulation - District Court of Arizona - Arizona

1 J. Daniel Campbell, Bar No. 005395
2 Lisa M. Hemann, Bar N0. 024703
O'CONNOR & CAMPBELL
3 3838 North Central Avenue
City Square Plaza, Suite 1800
4 Phoenix, Arizona 85012
5 [email protected]
(602) 241-7000
6
Attorneys for Defendants Farid Meshkatai
7 and Anita Kramer Meshkatai, Individually
8 and as trustee of the Anita Kramer Living
Trust, and Non-/Party Yariv E/azar
9
IO UNITED STATES DISTRICT COURT
ll
DISTRICT OF ARIZONA
12
lg FIDELITY NATIONAL FINANCIAL, )
INC., a Delaware Corporation; and ) Case No.: 03 1222 PHX RCB
14 FIDELITY EXPRESS NETWORK, )
15 INC., a California Corporation, )
)
_ 1 6 Plaintiffs, )
vs. )
17 COLIN H. FRIEDMAN, individually and) JOINT STIPULATION AND
as trustee of the Friedman Family Trust) [PROPOSED] ORDER
18 UDT, dated July 23,1987; HEDY )
lg KRAMER FRIEDMAN, individually and )
as trustee of the Friedman Family Trust)
20 UDT, dated July 23, 1987; FARID )
2l MESHKATAI, an individual; and ANITA)
KRAMER MESHKATAI, individually )
22 and as trustee of the Anita Kramer )
Living Trust, dated July 23, 1987, )
23 )
24 Defendants. )
>
25
2 6
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se 2:03—cv—01222-RCB Document 146 Filed 03/02/2007 Page 1 of4

1 Plaintiffs-Creditors Fidelity National Financial, Inc., and Fidelity Express
2 Network, Inc. ("Creditors"), and Defendant-Debtor Farid I\/leshkatai ("Debtor"),
3 by and through their attorneys of record herein stipulate as follows:
4 1. Creditors hold a judgment against Debtor issued by the District
5 Court for the Central District of California in Case No. CV00-06902-GAF (RZx)
6 (the "CaIifornia Action").
7 2. To enforce the judgment in Arizona, the state where Debtor
8 resides, Creditors filed the instant action with the Court.
9 3. On January 22, 2007, this Court issued an order requiring Debtor to
19 appear on l\/larch 5, 2007 at 9:00 a.m. for his debtor exam and produce certain
11 documents at least two weeks before the exam.
12 4. On January 29, 2007, the California Action Court issued its order
13 setting Debtor’s exam for February 26, 2007, at 10:00 a.m. A true and correct
14 copy of the January 29"‘ Order is attached hereto as Exhibit 1.
15 5. Counsel for Creditors and Debtor’s California counsel met and
16 conferred, and on February 21, 2007 entered into a stipulation to vacate this
17 Court’s January 22"d Order and the California Action Court’s January 29"‘
18 Order. Instead, the parties stipulated to proceed with one debtor exam before
19 the California court. The February 215* Stipulation also was signed by Debtor
20 Farid Meshkatai. A true and correct copy of the February 21S* Stipulation
21 entered is attached hereto as Exhibit 2.
22 6. On February 26, 2007 the California Action Court issued an order
23 reflecting the stipulation and requiring Debtor to appear for his debtor’s exam in
24 California. A true and correct copy of the February 26"‘ Order is attached
25 hereto as Exhibit 3.
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se 2:O3—cv—O1222-RCB Document 146 Filed O3/O2/2007 Page 2 of 4

0.3/02/07 FRI 15:56 FAX 3103052118 Hennelly & Grossfeld LLP 001 g
- · 4 7. ln light of the February 21S` Stipulation entered in California, l
2 attached as Exhibit 2, and the February 26"‘ Order entered in California,
3 attached as Exhibit 3, Creditors and Debtor’s Arizona counsel hereby stipulate
4 to vacate this Court’s January 22“d Order.
· 5 8. Counsel hereby agree that faxed signatures shall be effective for
6 the purposes of this stipulation. -
7 RESPECTFULLY SUBMITTED this 2"" day of March, 2007.
8 O’CONNOR & CAMPBELL
s
10 °/ I
l.!l ';’/lllji y',_ A _' ‘
11 b ntei Ca ben
12 Lisa M. Hemann
Attorneys for Defendants Farid lt/leshkatai .
_ 13 and Anita Kramer Meshkatai, individually
and as trustee of the Anita Kramer
M Living - and Non—Party Yariv Elazar
15
16 lj · D GRQSSFELD, LLP
19 · •‘ n J. l-lennelly, Esq.
Orlando Cabanday, Esq.
20 _ _ =-=..
21 —
Attorneys for Plaintiffs FIDELITY
gg NATIONAL FINANCIAL, INC., AND
23 FlDELlTY EXPRESS NETWORK, lNC.
24
25
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Case 2:O3—cv—O1222-RCB Document 146 Filed O3/O2/2007 Page 3 of 4 {

1 CERTIFICATE OF SERVICE
2 I hereby certify that on the day of l\/larch, 2007, I electronically
3 transmitted the attached document to the CIerk’s Office using the CM/ECF
System for filing and transmittal of a Notice of Electronic Filing to the following
4 CIVI/ECF registrants:
5 John J. Hennelly
6 Orlando F. Cabanday
HENNELLY & GROSSFELD,.L.L.P.
7 4640 Admiralty Way, Suite 850
8 Marina del Rey, CA 90292
Attorneys for Plaintiffs and Judgment Debtor’s
9 Fidelity National Financial, lnc. And
10 Fidelity Express Network, lnc.
ll Allen Hyman
Christine Coverdale
12 LAW OFFICES OF ALLEN HYMAN
B 10737 Riverside Drive
North Hollywood, CA 91602
14 Attorneys for Defendants Colin Friedman,
Hedy Kramer Friedman, Farid Meshkatai,
15 Anita Kramer Meshkatai, Laraine Ross,
16 Space Planners, LLC and Executive Legal Network
17
18 By: lsl Janet Neilson
19
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