The opinion of the court was delivered by: Judge: Mag. Carolyn K. Delaney
ANDREW T. CAULFIELD, SBN 238300 RICHARD H. CAULFIELD, SBN 50258 CAULFIELD LAW FIRM 1101 Investment Blvd., Suite 120 El Dorado Hills, CA 95762 Telephone: (916) 933-3200 Facsimile: (916) 605-4075 email@example.com Attorneys for Defendant El Dorado County Fair Association, Inc.
STIPULATION AND PROPOSED ORDER RE REQUESTED DISCOVERY SANCTIONS
Hearing Date: June 20, 2012 Hearing Time: 10:00 a.m. Location: Courtroom 26
Trial Date: March 26, 2013
Plaintiff PNC EQUIPMENT FINANCE, LLC ("Plaintiff"), and Defendant/Counterclaimant/Cross-Claimant EL DORADO COUNTY FAIR ASSOCIATION, INC. 3 ("EDCFA") (collectively, "the Parties"), by and through their undersigned counsel, hereby stipulate 4 to the following: 5
1.WHEREAS, on May 11, 2012, EDCFA filed a Motion for Discovery Sanctions and Motion to Compel Production of Documents ("the Motion").
2.WHEREAS, the Parties engaged in several meet and confer discussions regarding the Motion. On May 24, 2012, the Parties filed their Joint Statement re Discovery Disagreement. (Dckt. No. 106).
3.WHEREAS, on June 3, 2012, the Parties filed a Stipulation and Proposed Order requesting a continuance of the original hearing date for the Motion. (Dckt. No. 108).
4.WHEREAS, on June 4, 2012, the Court issued an Order continuing the Motion hearing date to June 20, 2012 at 10:00 a.m. in Courtroom 26. (Dckt. No. 109).
5.WHEREAS, the Parties have now resolved all issues related to sanctions requested by both Parties in the Motion (EDCFA) and Joint Statement re Discovery Dispute (EDCFA and PNC). The Parties hereby withdraw all of their respective requests for sanctions relating to the Motion.
6.WHEREAS, all remaining issues identified in the Motion remain in dispute. The Parties, however, will continue to meet and confer relating to the remaining issues identified in the Motion and will notify the Court of any resolutions reached.
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS:
1.All requests for sanctions made by both Parties relating to EDCFA's Motion for Discovery Sanctions and Motion to Compel Production of Documents, as set forth in the Motion and/or the Joint Statement re Discovery Disagreement, are hereby withdrawn. The Court will not issue a ...