On September 08, 2010 a
Stipulation,Agreement
was filed
involving a dispute between
Commonwealth Land Title Insurance Company,
Hwang, Shirley S.,
Fedex Office And Print Services, Inc,
Lum, Winston,
Merchants Bonding Company,
and
Aeschbacher, Bruno,
Afraimi, Morad,
Does 1-25,
Does 1-50,
Emerich, Melvin Lee,
Fedex Office And Print Services, Inc,
Fellmann, Stephen,
Languban, Grachelle,
Lum, Winston,
Lum,, Winston,
Martini & Chnoogle,
Martini & Chnoogle, Inc.,
Megan & Kasi Properties Llc,
Merchants Bonding Company,
M & K Properties, Llc,
Niroula, Kaushal,
Palomino, Elvia,
Replogle, David P.O. Box,
Shah, Jay Chandrakant Ap3101 California Medical Faci Vacaville, Ca 95696,
Hwang, Shirley S.,
for civil
in the District Court of San Francisco County.
Preview
IEA
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Jun-08-2017 11:34 am
Case Number: CGC-10-503332
Filing Date: Jun-08-2017 11:30
Filed by: ERICKA LARNAUTI
Image: 05896374
ORDER
COMMONWEALTH LAND TITLE INSURANCE COMPANY VS. FEDEX OFFICE
AND PRINT SERVICES, INC et al (PROVIDE ACCESS)
001005896374
Instructions:
Please place this sheet on top of the document to be scanned.1.48678
Ceo IN DW FF YW NY
v RoR YN Boe eee - =
FIDELITY NATIONAL LAW GROUP
HOWARD P. BRODY (SBN 65307)
915 Wilshire Boulevard, Suite 2100
Los Angeles, California 90017
Telephone: (213) 438-4414
Facsimile: (213) 438-4417
Email: howard.brody@fnf.com
Attorneys for Plaintiff,
COMMONWEALTH LAND TITLE
INSURANCE COMPANY
D
San Francisco County Superior Court
JUN U8 2017
SLERESE THE COURT _—
BY: Deputy Cle!
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
COMMONWEALTH LAND TITLE
INSURANCE COMPANY,
Plaintiffs,
v.
FEDEX OFFICE AND PRINT SERVICES,
INC.; WINSTON LUM; KAUSHAL
NIROULA; JAY CHANDRAKANT SHAH;
ELVIA PALOMINO; MORAD AFRAIMI;
MELVIN LEE EMERICH; MARTINI &
CHNOOGLE; GRACHELLE LANGUBAN;
MERCHANTS BONDING COMPANY, and
DOES 1-25, inclusive,
Defendants.
SHIRLEY S. HWANG,
Plaintiff,
Vv.
FEDEX OFFICE AND PRINT SERVICES,
INC.; WINSTON LUM; KAUSHAL
NIROULA; JAY CHANDRAKANT SHAH;
ELVIA PALOMINO; MORAD AFRAIMI;
MELVIN LEE EMERICH; GRACHELLE
LANGUBAN; MARTINI & CHNOOGLE, and
DOES 1-50,
Cross-Defendants.
CASE NO. CGC-10-503332
(Consolidated for all purposes with CGC-11-
512102)
Our (&
SK AND REQUEST TO
RETAIN JURISDICTION PURSUANT TO
C.C.P. SECTION 664.6
Trial Date: June 12, 2017
Time: 9:30 a.m.
Dept.: 302
STIPULATION AND REQUEST TO RETAIN JURISDICTION PURSUANT TO C.C.P. SECTION 664.6148678
C0 Om YN DH FF BW NY He
NN NY NY NY N NN NY Be Be Be we Be ewe Be ein
aon aA uw BN F&F SGD we NAY DH BF BW NH SF
TO THE HONORABLE JUDGE HAROLD E. KAHN AND ALL PARTIES AND THEIR
ATTORNEYS OF RECORD HEREIN:
IT IS HEREBY AGREED AND STIPULATED that the above entitled matter is settled
and on confidential terms and conditions ONLY as to Plaintiff Commonwealth Land Title
Insurance Company and Defendants Jay C. Shah and Elvia Palomino. The Settlement Agreement
and its appended Exhibit “A’ is agreed to be enforceable as between Plaintiff Commonwealth
Land Title Insurance Company and Defendants Jay Chandrakant Shah and Elvia Palomino.
It is hereby requested by Counsel for and Plaintiff Commonwealth Land Title Company
and Counsel for and Defendants Jay Chandrakant Shah and Elvia Palomino that your Court retain
jurisdiction and move to have a future date set for an Order to Show Cause regarding settlement
completion to November 30, 2017.
Furthermore;
1. Plaintiff Commonwealth will file a dismissal with prejudice, on or before
November 30, 2017 if the terms of the Settlement Agreement are fully satisfied by the
Defendants.
2. The Settlement Agreement may be enforced and your Court shall retain
jurisdiction pursuant to California Code of Civil Procedure § 664.6. The parties agree that on a
failure to comply with any of the terms of this settlement by any party, the other party may apply
ex parte for entry of judgment on ex parte notice and motion to opposing counsel(s) and shall be
entitled to reasonable attorney’s fees and costs incurred in filing an ex parte motion. The parties
further agree that the Settlement Agreement and its Exhibit “A” may be introduced into evidence
in any proceeding to enforce its terms should any party default on the terms of the Settlement
Agreement.
3. Each party agrees to perform all acts and execute and deliver all writings and
documents necessary to carry out the purpose and intent of the Settlement Agreement.
(Signatures continued on next page)
2
STIPULATION AND REQUEST TO RETAIN JURISDICTION PURSUANT TO C.C.P. SECTION 664.6t Dated: June f, 2017 FIDELITY NATIONAL LAW GROUP
| 2 LAO
3 HOWARD P. BRODY, Esq.
| Attorney for Plaintiff
| 4 COMMONWEALTH LAND TITLE
5 INSURANCE COMPANY
6 Dated: June , 2017 . COMMONWEALTH LAND TITLE
7 INSURANCE COMPANY
8
AMY PEITZ, Esq.
9 Assistant Vice President for
COMMONWEALTH LAND TITLE
10 INSURANCE COMPANY
; 11
Dv Dated: June , 2017
|
| 13
14 JAY CHANDRAKANT SHAH
Defendant
1 15 . .
i 16 Dated: June » 2017
17
18 _ GENE HALAVANAU, Esq.
Attorney for Defendant
19 JAY CHANDRAKANT SHAH
| 20 Dated: June » 2017
{ .
» Pra,
yy Of ote ght
ELVIA PALOMINO
23 :
i 24 Dated: June 7 »2017
25
26 , CG - BASSETT, Esq,
Attorney for Defendant
7 : ELVIA PALOMINO
t
28
‘148678, 3 —
STIPULATION AND REQUEST TO RETAIN JURISDICTION PURSUANT TO C.C.P. SECTION 664.6148678
ec em rQAA WR YN =
S
Dated: June , 2017
Dated: June , 2017
Dated: June 52017
Dated: June } , 2017
Dated: June > 2017
Dated: June , 2017
FIDELITY NATIONAL LAW GROUP
HOWARD P. BRODY, Esq.
Attorney for Plaintiff
COMMONWEALTH LAND TITLE
INSURANCE COMPANY
COMMONWEALTH LAND TITLE
INSURANCE COMPANY
AMY PEITZ, Esq.
Assistant Vice President for
COMMONWEALTH LAND TITLE
INSURANCE COMPANY
GE LAVANAU, Esq.
Attorney for Defendant
JAY CHANDRAKANT SHAH
ELVIA PALOMINO
CRAIG J. BASSETT, Esq.
Attorney for Defendant
ELVIA PALOMINO
3
STIPULATION AND REQUEST TO RETAIN JURISDICTION PURSUANT TO C.C_P, SECTION 664.6148678
NN YN N NON WV Soe eke et
ee Y’ehRBSRSSESERREEBHES
co wm IY DAH BF WN
Dated: June€>_, 2017
Dated: June 1 » 2017
Dated: June___, 2017
Dated: June » 2017
Dated: June , 2017
Dated; June 2017
—
FIDELITY NATIONAL LAW GROUP
“HOWARD ?-BRODY. Eg SS
Attorney for Plaintiff
COMMONWEALTH LAND TITLE
INSURANCE COMPANY
COMMONWEALTH LAND TITLE
INSURANCE COMPANY
SEA
Assis!
COMMONWEALTH LAND TITLE
INSURANCE COMPANY
JAY CHANDRAKANT SHAH
Defendant
GENE HALAVANAU, Esq.
Attorney for Defendant
JAY CHANDRAKANT SHAH
ELVIA PALOMINO
CRAIG J, BASSETT, Esq.
Attorney for Defendant
ELVIA PALOMINO
3
STIPULATION AND REQUEST TO RETAIN JURISDICTION PURSUANT TO C.C.P, SECTION 664.6148678
oOo ND WH FF WN
NY NNR RN NY Be Be Be Be ee Be Be eB
A Bo NY = SS © we QA AA RF BN FS
26
27
28
ABROPOSED] ORDER
This Court having reviewed the parties’ stipulation that the above entitled matter is settled
and on confidential terms and conditions ONLY as to Plaintiff Commonwealth Land Title
Insurance Company and Defendants Jay C. Shah and Elvia Palomino. The Settlement Agreement
and its appended Exhibit “A’ is agreed to be enforceable as between Plaintiff Commonwealth
Land Title Insurance Company and Defendants Jay Chandrakant Shah and Elvia Palomino.
IT IS HEREBY ORDERED:
The Court shall retain jurisdiction and shall set future date for an Order to Show Cause
regarding settlement completion to November 30, 2017.
Dated: June ¢ » 2017
~JUBGEHARGED-EACAH: —
RONALD E. QUIDACHAY
Judge db tne SupeniorCout
4
STIPULATION AND REQUEST TO RETAIN JURISDICTION PURSUANT TO C.C.P. SECTION 664.6
Preview
IEA SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Jun-08-2017 11:34 am Case Number: CGC-10-503332 Filing Date: Jun-08-2017 11:30 Filed by: ERICKA LARNAUTI Image: 05896374 ORDER COMMONWEALTH LAND TITLE INSURANCE COMPANY VS. FEDEX OFFICE AND PRINT SERVICES, INC et al (PROVIDE ACCESS) 001005896374 Instructions: Please place this sheet on top of the document to be scanned.1.48678 Ceo IN DW FF YW NY v RoR YN Boe eee - = FIDELITY NATIONAL LAW GROUP HOWARD P. BRODY (SBN 65307) 915 Wilshire Boulevard, Suite 2100 Los Angeles, California 90017 Telephone: (213) 438-4414 Facsimile: (213) 438-4417 Email: howard.brody@fnf.com Attorneys for Plaintiff, COMMONWEALTH LAND TITLE INSURANCE COMPANY D San Francisco County Superior Court JUN U8 2017 SLERESE THE COURT _— BY: Deputy Cle! SUPERIOR COURT FOR THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO COMMONWEALTH LAND TITLE INSURANCE COMPANY, Plaintiffs, v. FEDEX OFFICE AND PRINT SERVICES, INC.; WINSTON LUM; KAUSHAL NIROULA; JAY CHANDRAKANT SHAH; ELVIA PALOMINO; MORAD AFRAIMI; MELVIN LEE EMERICH; MARTINI & CHNOOGLE; GRACHELLE LANGUBAN; MERCHANTS BONDING COMPANY, and DOES 1-25, inclusive, Defendants. SHIRLEY S. HWANG, Plaintiff, Vv. FEDEX OFFICE AND PRINT SERVICES, INC.; WINSTON LUM; KAUSHAL NIROULA; JAY CHANDRAKANT SHAH; ELVIA PALOMINO; MORAD AFRAIMI; MELVIN LEE EMERICH; GRACHELLE LANGUBAN; MARTINI & CHNOOGLE, and DOES 1-50, Cross-Defendants. CASE NO. CGC-10-503332 (Consolidated for all purposes with CGC-11- 512102) Our (& SK AND REQUEST TO RETAIN JURISDICTION PURSUANT TO C.C.P. SECTION 664.6 Trial Date: June 12, 2017 Time: 9:30 a.m. Dept.: 302 STIPULATION AND REQUEST TO RETAIN JURISDICTION PURSUANT TO C.C.P. SECTION 664.6148678 C0 Om YN DH FF BW NY He NN NY NY NY N NN NY Be Be Be we Be ewe Be ein aon aA uw BN F&F SGD we NAY DH BF BW NH SF TO THE HONORABLE JUDGE HAROLD E. KAHN AND ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN: IT IS HEREBY AGREED AND STIPULATED that the above entitled matter is settled and on confidential terms and conditions ONLY as to Plaintiff Commonwealth Land Title Insurance Company and Defendants Jay C. Shah and Elvia Palomino. The Settlement Agreement and its appended Exhibit “A’ is agreed to be enforceable as between Plaintiff Commonwealth Land Title Insurance Company and Defendants Jay Chandrakant Shah and Elvia Palomino. It is hereby requested by Counsel for and Plaintiff Commonwealth Land Title Company and Counsel for and Defendants Jay Chandrakant Shah and Elvia Palomino that your Court retain jurisdiction and move to have a future date set for an Order to Show Cause regarding settlement completion to November 30, 2017. Furthermore; 1. Plaintiff Commonwealth will file a dismissal with prejudice, on or before November 30, 2017 if the terms of the Settlement Agreement are fully satisfied by the Defendants. 2. The Settlement Agreement may be enforced and your Court shall retain jurisdiction pursuant to California Code of Civil Procedure § 664.6. The parties agree that on a failure to comply with any of the terms of this settlement by any party, the other party may apply ex parte for entry of judgment on ex parte notice and motion to opposing counsel(s) and shall be entitled to reasonable attorney’s fees and costs incurred in filing an ex parte motion. The parties further agree that the Settlement Agreement and its Exhibit “A” may be introduced into evidence in any proceeding to enforce its terms should any party default on the terms of the Settlement Agreement. 3. Each party agrees to perform all acts and execute and deliver all writings and documents necessary to carry out the purpose and intent of the Settlement Agreement. (Signatures continued on next page) 2 STIPULATION AND REQUEST TO RETAIN JURISDICTION PURSUANT TO C.C.P. SECTION 664.6t Dated: June f, 2017 FIDELITY NATIONAL LAW GROUP | 2 LAO 3 HOWARD P. BRODY, Esq. | Attorney for Plaintiff | 4 COMMONWEALTH LAND TITLE 5 INSURANCE COMPANY 6 Dated: June , 2017 . COMMONWEALTH LAND TITLE 7 INSURANCE COMPANY 8 AMY PEITZ, Esq. 9 Assistant Vice President for COMMONWEALTH LAND TITLE 10 INSURANCE COMPANY ; 11 Dv Dated: June , 2017 | | 13 14 JAY CHANDRAKANT SHAH Defendant 1 15 . . i 16 Dated: June » 2017 17 18 _ GENE HALAVANAU, Esq. Attorney for Defendant 19 JAY CHANDRAKANT SHAH | 20 Dated: June » 2017 { . » Pra, yy Of ote ght ELVIA PALOMINO 23 : i 24 Dated: June 7 »2017 25 26 , CG - BASSETT, Esq, Attorney for Defendant 7 : ELVIA PALOMINO t 28 ‘148678, 3 — STIPULATION AND REQUEST TO RETAIN JURISDICTION PURSUANT TO C.C.P. SECTION 664.6148678 ec em rQAA WR YN = S Dated: June , 2017 Dated: June , 2017 Dated: June 52017 Dated: June } , 2017 Dated: June > 2017 Dated: June , 2017 FIDELITY NATIONAL LAW GROUP HOWARD P. BRODY, Esq. Attorney for Plaintiff COMMONWEALTH LAND TITLE INSURANCE COMPANY COMMONWEALTH LAND TITLE INSURANCE COMPANY AMY PEITZ, Esq. Assistant Vice President for COMMONWEALTH LAND TITLE INSURANCE COMPANY GE LAVANAU, Esq. Attorney for Defendant JAY CHANDRAKANT SHAH ELVIA PALOMINO CRAIG J. BASSETT, Esq. Attorney for Defendant ELVIA PALOMINO 3 STIPULATION AND REQUEST TO RETAIN JURISDICTION PURSUANT TO C.C_P, SECTION 664.6148678 NN YN N NON WV Soe eke et ee Y’ehRBSRSSESERREEBHES co wm IY DAH BF WN Dated: June€>_, 2017 Dated: June 1 » 2017 Dated: June___, 2017 Dated: June » 2017 Dated: June , 2017 Dated; June 2017 — FIDELITY NATIONAL LAW GROUP “HOWARD ?-BRODY. Eg SS Attorney for Plaintiff COMMONWEALTH LAND TITLE INSURANCE COMPANY COMMONWEALTH LAND TITLE INSURANCE COMPANY SEA Assis! COMMONWEALTH LAND TITLE INSURANCE COMPANY JAY CHANDRAKANT SHAH Defendant GENE HALAVANAU, Esq. Attorney for Defendant JAY CHANDRAKANT SHAH ELVIA PALOMINO CRAIG J, BASSETT, Esq. Attorney for Defendant ELVIA PALOMINO 3 STIPULATION AND REQUEST TO RETAIN JURISDICTION PURSUANT TO C.C.P, SECTION 664.6148678 oOo ND WH FF WN NY NNR RN NY Be Be Be Be ee Be Be eB A Bo NY = SS © we QA AA RF BN FS 26 27 28 ABROPOSED] ORDER This Court having reviewed the parties’ stipulation that the above entitled matter is settled and on confidential terms and conditions ONLY as to Plaintiff Commonwealth Land Title Insurance Company and Defendants Jay C. Shah and Elvia Palomino. The Settlement Agreement and its appended Exhibit “A’ is agreed to be enforceable as between Plaintiff Commonwealth Land Title Insurance Company and Defendants Jay Chandrakant Shah and Elvia Palomino. IT IS HEREBY ORDERED: The Court shall retain jurisdiction and shall set future date for an Order to Show Cause regarding settlement completion to November 30, 2017. Dated: June ¢ » 2017 ~JUBGEHARGED-EACAH: — RONALD E. QUIDACHAY Judge db tne SupeniorCout 4 STIPULATION AND REQUEST TO RETAIN JURISDICTION PURSUANT TO C.C.P. SECTION 664.6