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David Rafanelli, An Individual; Patricia Rafanelli, An v. Travelers

December 28, 2012

DAVID RAFANELLI, AN INDIVIDUAL; PATRICIA RAFANELLI, AN INDIVIDUAL; A. RAFANELLI WINERY & VINEYARDS LIMITED PARTNERSHIP DBA A. RAFANELLI WINERY & VINEYARDS, A CALIFORNIA LIMITED PARTNERSHIP; RAFANELLI MANAGEMENT LLC, A CALIFORNIA LIMITED LIABILITY COMPANY; RASHELL L. RAFANELLI-FEHLMAN AN INDIVIDUAL; AND RLF MANAGEMENT LLC, A CALIFORNIA LIMITED LIABILITY COMPANY; PLAINTIFFS,
v.
TRAVELERS PROPERTY CASUALTY COMPANY OF AMERICA, A CONNECTICUT CORPORATION, DEFENDANT.



NOTICE OF SETTLEMENT OF ENTIRE CASE AND STIPULATION AND [PROPOSED] ORDER VACATING MOTION HEARING

DATE Assigned To: Hon. Samuel Conti Trial Date: Not Set

TO THE CLERK OF THE COURT AND ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE that on or about December 20, 2012 Plaintiffs David Rafanelli, Patricia Rafanelli, A. Rafanelli Winery & Vineyards Limited Partnership dba A. 5 Rafanelli Winery & Vineyards, Rafanelli Management LLC, Rashell L. Rafanelli-Fehlman and 6 RLF Management LLC (collectively "Rafanelli") and Defendant Travelers Property Casualty 7 Company of America ("Travelers") (together the "Parties") agreed to the terms of a conditional 8 settlement. 9

This stipulation is entered into by the Parties by and through their respective counsel of 10 record. 11 12

FACTUAL RECITALS

This Stipulation is entered into in reference to the following facts:

1. The initial pleading in this case was filed on August 6, 2012.

2. The Parties have pending motions for summary judgment set for hearing on January 11, 2012 which the Parties wish to withdraw.

3. The Parties anticipate that it will take 30 days to finalize the settlement agreement and for Travelers to satisfactorily complete the terms of the settlement.

4. The Parties anticipate that they will be able to file a stipulation of dismissal within approximately 45 days.

STIPULATION

In light of the foregoing facts, the Parties agree as follows:

1. The hearing date on the motions for summary judgment scheduled for January 11, ...


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