Filed: Apr. 03, 2019
Latest Update: Apr. 03, 2019
Summary: JOINT REPORT REGARDING SETTLEMENT AND STIPULATION TO CONTINUE REPORT DEADLINE; PROPOSED ORDER [Originally California Superior Court (Sacramento) Case No. 34-2018-00235596] JOHN A. MENDEZ , District Judge . Defendant PRIMEFLIGHT AVIATION SERVICES, INC. WHICH WILL DO BUSINESS IN CALIFORNIA AS PRIMEFLIGHT OF DE, INC. (hereinafter, "PrimeFlight — DE") and Plaintiff HERTA GUADALUPE KUHN (hereinafter, "Plaintiff") (hereinafter, collectively, the "Parties") hereby stipulate as follows. WHEREAS,
Summary: JOINT REPORT REGARDING SETTLEMENT AND STIPULATION TO CONTINUE REPORT DEADLINE; PROPOSED ORDER [Originally California Superior Court (Sacramento) Case No. 34-2018-00235596] JOHN A. MENDEZ , District Judge . Defendant PRIMEFLIGHT AVIATION SERVICES, INC. WHICH WILL DO BUSINESS IN CALIFORNIA AS PRIMEFLIGHT OF DE, INC. (hereinafter, "PrimeFlight — DE") and Plaintiff HERTA GUADALUPE KUHN (hereinafter, "Plaintiff") (hereinafter, collectively, the "Parties") hereby stipulate as follows. WHEREAS, t..
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JOINT REPORT REGARDING SETTLEMENT AND STIPULATION TO CONTINUE REPORT DEADLINE; PROPOSED ORDER
[Originally California Superior Court (Sacramento) Case No. 34-2018-00235596]
JOHN A. MENDEZ, District Judge.
Defendant PRIMEFLIGHT AVIATION SERVICES, INC. WHICH WILL DO BUSINESS IN CALIFORNIA AS PRIMEFLIGHT OF DE, INC. (hereinafter, "PrimeFlight — DE") and Plaintiff HERTA GUADALUPE KUHN (hereinafter, "Plaintiff") (hereinafter, collectively, the "Parties") hereby stipulate as follows.
WHEREAS, the Parties have reached a settlement, Plaintiff will file a motion for preliminary approval once the settlement has been formalized in long-form agreement. As such, the parties request a further report deadline by no later than April 29, 2019.
NOW THEREFORE, it is so stipulated, as set forth above.
Respectfully submitted,
Dated: March 29, 2019
FISHER & PHILLIPS LLP
By: /s/ Christopher M. Ahearn
COLLIN D. COOK
CHRISTOPHER M. AHEARN
Attorneys For Defendant
PRIMEFLIGHT AVIATION SERVICES,
INC. WHICH WILL DO BUSINESS IN
CALIFORNIA AS PRIMEFLIGHT OF DE,
INC.
Dated: March 29, 2019 Respectfully submitted,
OTKUPMAN LAW FIRM, A LAW
CORPORATION
By: /s/ Roman Otkupman
(as authorized on March 29, 2019)
ROMAN OTKUPMAN
MEGHAN MAERTZ
Attorneys for Plaintiff
HERTA GUADALUPE KUHN
[PROPOSED] ORDER
Good cause appearing, the Court orders that:
(1) The parties shall file a further joint status report, not later than April 29, 2019. If Plaintiff has filed a motion for preliminary approval of settlement by such date, no report will be necessary.
IT IS SO ORDERED.
