Free Stipulation - District Court of California - California

Case 3:07-cv-04015-MMC

Document 35

Filed 05/05/2008

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LINDA JOY KATTWINKEL, ESQ. (S.B.N. 164283) BROOKE OLIVER, ESQ. (S.B.N. 172828) OLIVER, KATTWINKEL & SABEC P.C. 50 Balmy Alley San Francisco, CA 94110 415-641-1116 voice 415-695-1116 fax [email protected] [email protected] LAWRENCE G. TOWNSEND, ESQ. (S.B.N. 88184) OWEN, WICKERSHAM & ERICKSON, P.C. 455 Market St., Ste. 1910 San Francisco, CA 94105 415-882-3200 voice 415-882-3232 fax [email protected] Attorneys for Plaintiffs, Leaf Lines LLC and Booker Morey UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA LEAF LINES LLC, a California Company, and BOOKER MOREY, a California state resident, Plaintiffs, vs. MICHAEL D. SAGE and SUSAN GILMOUR SAGE, Washington state residents, dba SAGE DESIGNS, and DOES 1-100, Defendants. / / / Plaintiffs Leaf Lines LLC and Booker Morey and Defendants Michael D. Sage and Susan Gilmour Sage, dba Sage Designs, by and through their respective attorneys of record, hereby stipulate as follows: No. C 07 4015 MMC STIPULATION TO FILE CONFIDENTIAL SETTLEMENT AGREEMENT UNDER SEAL AND [PROPOSED] ORDER

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[C07-4015 MMC] STIPULATION TO FILE SETTLEMENT AGREEMENT UNDER SEAL AND [PROPOSED] ORDER

Case 3:07-cv-04015-MMC

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1.

The parties have entered into a confidential Settlement Agreement and

Mutual Release (the "Settlement Agreement") in this matter whereby they have resolved all claims in this action and have agreed to the dismissal of the above-captioned action with prejudice. Each party has agreed to bear its own attorneys' fees and costs. 2. The parties filed a Stipulation of Dismissal with Prejudice on April 24, 2008,

wherein the parties requested that the Court retain jurisdiction over the action for the purpose of enforcing their Settlement Agreement. 3. By Order dated April 25, 2008, the Court required that the parties file a copy

of the Settlement Agreement so that the Court can determine whether retention of jurisdiction is appropriate. 4. 5. By its terms, the entire Settlement Agreement must remain confidential. Accordingly, the parties jointly request the Court to order that the Settlement

Agreement be filed under seal. OLIVER, KATTWINKEL & SABEC P.C. OWEN, WICKERSHAM & ERICKSON, P.C.

Dated: May 2, 2008

/s/ Linda Joy Kattwinkel Attorneys for Plaintiffs, Leaf Lines LLC and Booker Morey

THE DUBOFF LAW GROUP

Dated: May 2, 2008

/s/ Christopher Brown Attorneys for Defendants Michael D. Sage and Susan Gilmour Sage, dba Sage Designs
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Case 3:07-cv-04015-MMC

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Filed 05/05/2008

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ORDER

Having considered the parties Stipulation and for good cause appearing, it is HEREBY ORDERED:

The Settlement Agreement in this action shall be filed under seal.

Dated: _____________________

___________________________________ The Honorable Maxine Chesney United States District Judge

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[C07-4015 MMC] STIPULATION TO FILE SETTLEMENT AGREEMENT UNDER SEAL AND [PROPOSED] ORDER