On June 27, 2019 a
Stipulation,Agreement
was filed
involving a dispute between
Binder Ed,
Summers Robert,
Cenveo Worldwide Limited A Delaware Corporation,
Cenveo Worldwilde Limited A Delaware Corporation,
and
Lithographix Inc.,
Minguez Ariel,
Summers Robert,
for Other Breach of Contract/Warranty (not fraud or negligence) (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
1 POLSINELLI LLP
Todd M. Malynn (SBN 181595)
2 tmalynn@polsinelli.com
Keia J. Atkinson (SBN 316649)
3 katkinson@polsinelli.com
2049 Century Park East, Suite 2900
4 Los Angeles, CA 90067
Telephone: (310) 556-1801
5 Facsimile: (310) 556-1802
Attorneys for Plaintiff Cenveo Worldwide Limited
6
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
COUNTY OF LOS ANGELES
9
10
CENVEO WORLDWIDE LIMITED, a Case No. 19STCV22712
11 Delaware corporation,
Hon. Dennis J. Landin
12 Plaintiff, Dept. 51
v.
13 ROBERT SUMMERS, an individual, JOINT STIPULATION RE: AMENDED
and DOES 1-10, inclusive, PLEADINGS; [PROPOSED] ORDER
2049 Century Park East, Suite 2900
Electronically Received 05/28/2020 09:37 AM
14
Defendants.
Action Filed: June 27, 2019
Los Angeles, CA 90067
15
(310) 556-1801
Polsinelli LLP
16
17 TO THE COURT AND COUNSEL OF RECORD:
18 Plaintiff Cenveo Worldwide Limited (“Plaintiff”) and defendant Robert Summers
19 (“Defendant”), by and through their counsel of record, with reference to the foregoing facts, hereby
20 stipulate and agree, and seek and order of the Court, as follows:
21 1. Pursuant to the prior joint stipulation, Defendant produced documents in advance of
22 and the parties participated in a mediation on May 12, 2020, before Mariam Zadeh; the parties are
23 continuing to discuss settlement with the mediator;
24 2. Plaintiff, based on Defendant’s document production, believes it is necessary and
25 appropriate to identify Doe Defendants “1” to “3” via amendment and to assert additional claims
26 both to prosecute the case and to facilitate settlement discussions; accordingly, Plaintiff
27 corresponded with Defendant and drafted and circulated a Third Amended Complaint;
28
JOINT STIPULATION TO FILE AMENDMENT AND AMENDED PLEADINGS
30
72840989.2
31 73725859.1
Document Filed Date
May 29, 2020
Case Filing Date
June 27, 2019
Category
Other Breach of Contract/Warranty (not fraud or negligence) (General Jurisdiction)
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 10/05/2020
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Preview
1 POLSINELLI LLP Todd M. Malynn (SBN 181595) 2 tmalynn@polsinelli.com Keia J. Atkinson (SBN 316649) 3 katkinson@polsinelli.com 2049 Century Park East, Suite 2900 4 Los Angeles, CA 90067 Telephone: (310) 556-1801 5 Facsimile: (310) 556-1802 Attorneys for Plaintiff Cenveo Worldwide Limited 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF LOS ANGELES 9 10 CENVEO WORLDWIDE LIMITED, a Case No. 19STCV22712 11 Delaware corporation, Hon. Dennis J. Landin 12 Plaintiff, Dept. 51 v. 13 ROBERT SUMMERS, an individual, JOINT STIPULATION RE: AMENDED and DOES 1-10, inclusive, PLEADINGS; [PROPOSED] ORDER 2049 Century Park East, Suite 2900 Electronically Received 05/28/2020 09:37 AM 14 Defendants. Action Filed: June 27, 2019 Los Angeles, CA 90067 15 (310) 556-1801 Polsinelli LLP 16 17 TO THE COURT AND COUNSEL OF RECORD: 18 Plaintiff Cenveo Worldwide Limited (“Plaintiff”) and defendant Robert Summers 19 (“Defendant”), by and through their counsel of record, with reference to the foregoing facts, hereby 20 stipulate and agree, and seek and order of the Court, as follows: 21 1. Pursuant to the prior joint stipulation, Defendant produced documents in advance of 22 and the parties participated in a mediation on May 12, 2020, before Mariam Zadeh; the parties are 23 continuing to discuss settlement with the mediator; 24 2. Plaintiff, based on Defendant’s document production, believes it is necessary and 25 appropriate to identify Doe Defendants “1” to “3” via amendment and to assert additional claims 26 both to prosecute the case and to facilitate settlement discussions; accordingly, Plaintiff 27 corresponded with Defendant and drafted and circulated a Third Amended Complaint; 28 JOINT STIPULATION TO FILE AMENDMENT AND AMENDED PLEADINGS 30 72840989.2 31 73725859.1