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Bikram - Gabrielle Raiz - Settlement

Bikram - Gabrielle Raiz - Settlement

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Published by byci
Bikram - Gabrielle Raiz - Settlement
Bikram - Gabrielle Raiz - Settlement

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Categories:Types, Business/Law
Published by: byci on Aug 20, 2013
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08/21/2013

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PARTIES’ JOINT SETTLEMENT REPORTAND STIP. TO VACATE SCHEDULINGORDER – 2:11-CV-07377 CBM (VBK)
12345678910111213141516171819202122232425262728DANIEL M. PETROCELLI (S.B. #97802)dpetrocelli@omm.comCARLA J. CHRISTOFFERSON (S.B. #161111)cchristofferson@omm.comO’MELVENY & MYERS LLP1999 Avenue of the Stars, 7th Floor Los Angeles, CA 90067Telephone: (310) 553-6700Facsimile: (310) 246-6779Attorneys for Plaintiffs and Counter-DefendantsBIKRAM’S YOGA COLLEGE OFINDIA, L.P. and BIKRAM CHOUDHURYJordan Susman (SBN 246116) jsusman@ftllp.comFREEDMAN & TAITELMAN LLP1901 Avenue of the Stars, Suite 500Los Angeles, California 90067Telephone: (310) 201-0005Facsimile: (310) 201-0045Attorneys for Defendants and CounterclaimantsGABRIELLE RAIZ and ROBERT SCANLON
UNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIA
BIKRAM’S YOGA COLLEGE OFINDIA, L.P.; a California limited partnership; and BIKRAMCHOUDHURY, an Individual,Plaintiffs,v.GABRIELLE RAIZ, aka GABRIELLESCANLON, an Individual, dba THEHOT YOGA DOCTOR; ROBERTSCANLON; an Individual; KATEEVANS, an Individual; and DOES 1through 10, inclusive,Defendants.Case No.
 
2:11-CV-07377 CBM (VBK)
PARTIES’ JOINT REPORTREGARDING STATUS OFSETTLEMENT DISCUSSIONS ANDSTIPULATION TO VACATESCHEDULING ORDER ANDRELATED CASE MANAGEMENTDEADLINES
[PROPOSED] ORDER LODGEDHEREWITHHon. Consuelo B. MarshallCourtroom 2AND RELATED COUNTERCLAIMS.
Case 2:11-cv-07377-CBM-VBK Document 87 Filed 07/30/13 Page 1 of 6 Page ID #:854
 
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PARTIES’ JOINT SETTLEMENT REPORTAND STIP. TO VACATE SCHEDULINGORDER – 2:11-CV-07377 CBM (VBK)
12345678910111213141516171819202122232425262728Plaintiffs and Counter-Defendants Bikram’s Yoga College of India, L.P. andBikram Choudhury (collectively, “Plaintiffs”) and Defendants andCounterclaimants Gabrielle Raiz and Robert Scanlon (collectively, “RaizDefendants”) (Plaintiffs and Raiz Defendants being collectively referred to hereinas the “Parties”), by and through their counsel, hereby give notice that they havereached a settlement in principle of all claims and counterclaims in the above-captioned action, have memorialized this settlement in a formal, near-finalDismissal and Tolling Agreement, and expect to finalize and execute the Dismissaland Tolling Agreement within the following fourteen (14) days.The Parties further stipulate as follows:WHEREAS, the Plaintiffs and Raiz Defendants are the only remaining parties to this action, as all other defendants have either been dismissed by theCourt or by the Parties or were never served with process;WHEREAS, the Court issued a Scheduling Order on November 20, 2012(“Scheduling Order”) [Doc. No. 78];WHEREAS, the Scheduling Order sets various case management deadlines,including a July 31, 2013 deadline for non-expert discovery and an August 30,2013 deadline for expert discovery;WHEREAS, on June 28, 2013 the Parties filed a Joint Notice of Settlementin Principle and Stipulation to Vacate Scheduling Order and Related CaseManagement Deadlines [Doc. No. 85];WHEREAS, on July 11, 2013, this Court issued an Order continuing all casemanagement deadlines set out in the Scheduling Order for 30 days and requiring theParties to file a joint report regarding settlement status no later than July 30, 2013(“Continuation Order”) [Doc. No. 86];WHEREAS, the Parties have now documented their settlement in a formal,near-final Dismissal and Tolling Agreement;
Case 2:11-cv-07377-CBM-VBK Document 87 Filed 07/30/13 Page 2 of 6 Page ID #:855
 
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PARTIES’ JOINT SETTLEMENT REPORTAND STIP. TO VACATE SCHEDULINGORDER – 2:11-CV-07377 CBM (VBK)
12345678910111213141516171819202122232425262728WHEREAS, the Parties have exchanged a near-final draft of the proposedDismissal and Tolling Agreement but require additional time to review, finalize andexecute that Agreement;WHEREAS, various discovery deadlines set in the Scheduling Order, ascontinued by the Continuation Order, are rapidly approaching;WHEREAS, the Parties desire to finalize and execute the Dismissal andTolling Agreement without incurring the litigation expenses necessary to complywith the discovery deadlines in the Scheduling Order, as continued by theContinuation Order;WHEREAS, the Parties expect to finalize and execute their Dismissal andTolling Agreement within fourteen (14) days and to file a joint stipulation todismiss without prejudice all claims and counterclaims asserted in the above-captioned action within twenty one (21) days;Accordingly, IT IS HEREBY STIPULATED AND AGREED ASFOLLOWS:In light of the imminent finalization and execution of the Dismissal andTolling Agreement, the Parties jointly request that the Court vacate the SchedulingOrder dated November 20, 2012 [Doc. No. 78] and all case management deadlinesarising therefrom as extended by the Continuation Order [Doc. No. 86], so that theParties may finalize and execute the Dismissal and Tolling Agreement and avoidwaste of judicial resources and further expenditure of potentially unnecessaryattorneys’ fees and costs.IT IS SO STIPULATED.
Case 2:11-cv-07377-CBM-VBK Document 87 Filed 07/30/13 Page 3 of 6 Page ID #:856

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