Preview
Electronically Filed
1/10/2019 11:46 AM
Superior Court of California
County of Stanislaus
Clerk of the Court
1 JEFFREY A. ROSENFELD (Bar No. 136896) By: Lori Salazar, Deputy
SEAN R. CRAIN (Bar No. 291515)
JONATHAN J. KIM (Bar No. 312145)
ALSTON & BIRD LLP
333 South Hope Street, Sixteenth Floor
Los Angeles, CA 90071
Telephone: (213) 576-1000
Facsimile: (213) 576-1100
Email: jeffrey.rosenfeld@alston.com
sean.crain @alston.com
jonathan.kim@alston.com
Attorneys for Defendant and Cross-Complainant
ORENS UNIVERSAL, INC. dba
PLAZA TRAVEL
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF STANISLAUS
JULI BLOXHAM Case No.: 2026233
fdba CRUISE COMPANY INC.,
Alston & Bird LLP
Assigned for all purposes to the Honorable Roger
Plaintiff, M. Beauchesne, Dept. 24
vs. NOTICE OF SETTLEMENT OF ENTIRE
CASE AND REQUEST TO CONTINUE CASE
ORENS UNIVERSAL, INC., dba PLAZA MANAGEMENT CONFERENCE
TRAVEL, STEPHEN LOZANO, and DOES
1 -50, inclusive,
Defendants.
ORENS UNIVERSAL, INC., dba PLAZA Complaint Filed: August 14, 2017
TRAVEL, Trial Date: None
Defendant and Cross-
Complainant,
vs.
JULI BLOXHAM fdba THE CRUISE
COMPANY INC., and ROES 1 through 10,
inclusive,
Plaintiffs and Cross-
Defendants.
NOTICE OF SETTLEMENT OF ENTIRE CASE AND REQUEST TO CONTINUE CMC
TO THE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE
TAKE NOTICE THAT Defendant and Cross-Complainant ORENS UNIVERSAL, INC., dba
PLAZA TRAVEL ("Orens") and Plaintiff and Cross-Defendant JULI BLOXAHM fdba THE CRUISE
COMPANY INC. ("Plaintiff') have reached a settlement in principal of the entire case, subject to and
conditioned upon the negotiation and execution of a long-form settlement agreement.
As such, for the purposes of judicial economy and efficiency, Orens respectfully requests that
the Court continue the case management conference currently scheduled for January 28, 2019, at 8:30
a.m., to a date at least 60 days thereafter, so the parties may finalize the settlement agreement and file
their respective dismissals.
DATED: January 10, 2019 ALSTON & BIRD LLP
By
JEFFREY A. ROSENFELD
SEAN R. CRAIN
JONATHAN J. KIM
Attorneys for Defendant and Cross-Complainant
ORENS UNIVERSAL, INC. dba PLAZA
TRAVEL
2
NOTICE OF SETTLEMENT OF ENTIRE CASE AND REQUEST TO CONTINUE CMG
PROOF OF SERVICE
I, Melinda Jimenez, declare:
I am employed in the County of Los Angeles, State of California. I am over the age of 18 and
not a party to the action in which this service is made. My business address is Alston & Bird LLP,
333 South Hope Street, Sixteenth Floor, Los Angeles, CA 90071.
On January 10, 2019, I served the document(s) described as NOTICE OF SETTLEMENT
OF ENTIRE CASE AND REQUEST TO CONTINUE CASE MANAGEMENT
CONFERENCE on the interested parties in this action by enclosing the document(s) in a sealed
envelope addressed as follows: See Attached Service List
BY MAIL: I am "readily familiar" with this firm's practice for the collection and the processing
of correspondence for mailing with the United States Postal Service. In the ordinary course of
business, the correspondence would be deposited with the United States Postal Service at 333
South Hope Street, Los Angeles, California 90071 with postage thereon fully prepaid the same
day on which the correspondence was placed for collection and mailing at the firm. Following
ordinary business practices, I placed for collection and mailing with the United States Postal
Service such envelope at Alston & Bird LLP, 333 South Hope Street, Los Angeles, California
90071.
❑ BY FEDERAL EXPRESS ❑ UPS NEXT DAY AIR ❑ OVERNIGHT DELIVERY: I
deposited such envelope in a facility regularly maintained by ❑ FEDERAL EXPRESS ❑
UPS ❑ Overnight Delivery [specify name of service: ] with delivery fees fully provided for
or delivered the envelope to a courier or driver of ❑ FEDERAL EXPRESS ❑ UPS ❑
OVERNIGHT DELIVERY [specify name of service:] authorized to receive documents at
Alston & Bird LLP, 333 South Hope Street, Los Angeles, California 90071 with delivery fees
fully provided for.
❑ BY HAND DELIVERY: By giving a true copy(ies) thereof in sealed envelope(s) to ACE
Messenger and Attorney Service, Inc. for hand delivery to: (SEE ATTACHED SERVICE
LIST)
❑ BY FACSIMILE: I telecopied a copy of said document(s) to the following addressee(s) at the
following number(s) in accordance with the written confirmation of counsel in this action.
• [State] I declare under penalty of perjury under the laws of the State of California that the above
is true and correct.
❑ [Federal] I declare under penalty of perjury under the laws of the United States of America
that the foregoing is true and correct.
Executed on January 10, 2019, at Los Angeles, California.
Melinda Jimenez
3
NOTICE OF SETTLEMENT OF ENTIRE CASE AND REQUEST TO CONTINUE CMC
Bloxham fdba Cruise Company vs. Orens Universal Inc. dba Plaza Travel
Case No. 2026233
SERVICE LIST
Mark Nelson Attorneys for Plaintiff
Derek Casey Juli Bloxham tbda Cruise Company, Inc.
LAW OFFICES OF MARK NELSON
215 McHenry Avenue
Modesto, California 95354
Telephone: (209) 529-0995
Facsimile: (209) 529-6207
Email: derek@marksnelson.com
4
NOTICE OF SETTLEMENT OF ENTIRE CASE AND REQUEST TO CONTINUE CMC
Preview
Electronically Filed 1/10/2019 11:46 AM Superior Court of California County of Stanislaus Clerk of the Court 1 JEFFREY A. ROSENFELD (Bar No. 136896) By: Lori Salazar, Deputy SEAN R. CRAIN (Bar No. 291515) JONATHAN J. KIM (Bar No. 312145) ALSTON & BIRD LLP 333 South Hope Street, Sixteenth Floor Los Angeles, CA 90071 Telephone: (213) 576-1000 Facsimile: (213) 576-1100 Email: jeffrey.rosenfeld@alston.com sean.crain @alston.com jonathan.kim@alston.com Attorneys for Defendant and Cross-Complainant ORENS UNIVERSAL, INC. dba PLAZA TRAVEL SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF STANISLAUS JULI BLOXHAM Case No.: 2026233 fdba CRUISE COMPANY INC., Alston & Bird LLP Assigned for all purposes to the Honorable Roger Plaintiff, M. Beauchesne, Dept. 24 vs. NOTICE OF SETTLEMENT OF ENTIRE CASE AND REQUEST TO CONTINUE CASE ORENS UNIVERSAL, INC., dba PLAZA MANAGEMENT CONFERENCE TRAVEL, STEPHEN LOZANO, and DOES 1 -50, inclusive, Defendants. ORENS UNIVERSAL, INC., dba PLAZA Complaint Filed: August 14, 2017 TRAVEL, Trial Date: None Defendant and Cross- Complainant, vs. JULI BLOXHAM fdba THE CRUISE COMPANY INC., and ROES 1 through 10, inclusive, Plaintiffs and Cross- Defendants. NOTICE OF SETTLEMENT OF ENTIRE CASE AND REQUEST TO CONTINUE CMC TO THE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE THAT Defendant and Cross-Complainant ORENS UNIVERSAL, INC., dba PLAZA TRAVEL ("Orens") and Plaintiff and Cross-Defendant JULI BLOXAHM fdba THE CRUISE COMPANY INC. ("Plaintiff') have reached a settlement in principal of the entire case, subject to and conditioned upon the negotiation and execution of a long-form settlement agreement. As such, for the purposes of judicial economy and efficiency, Orens respectfully requests that the Court continue the case management conference currently scheduled for January 28, 2019, at 8:30 a.m., to a date at least 60 days thereafter, so the parties may finalize the settlement agreement and file their respective dismissals. DATED: January 10, 2019 ALSTON & BIRD LLP By JEFFREY A. ROSENFELD SEAN R. CRAIN JONATHAN J. KIM Attorneys for Defendant and Cross-Complainant ORENS UNIVERSAL, INC. dba PLAZA TRAVEL 2 NOTICE OF SETTLEMENT OF ENTIRE CASE AND REQUEST TO CONTINUE CMG PROOF OF SERVICE I, Melinda Jimenez, declare: I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the action in which this service is made. My business address is Alston & Bird LLP, 333 South Hope Street, Sixteenth Floor, Los Angeles, CA 90071. On January 10, 2019, I served the document(s) described as NOTICE OF SETTLEMENT OF ENTIRE CASE AND REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE on the interested parties in this action by enclosing the document(s) in a sealed envelope addressed as follows: See Attached Service List BY MAIL: I am "readily familiar" with this firm's practice for the collection and the processing of correspondence for mailing with the United States Postal Service. In the ordinary course of business, the correspondence would be deposited with the United States Postal Service at 333 South Hope Street, Los Angeles, California 90071 with postage thereon fully prepaid the same day on which the correspondence was placed for collection and mailing at the firm. Following ordinary business practices, I placed for collection and mailing with the United States Postal Service such envelope at Alston & Bird LLP, 333 South Hope Street, Los Angeles, California 90071. ❑ BY FEDERAL EXPRESS ❑ UPS NEXT DAY AIR ❑ OVERNIGHT DELIVERY: I deposited such envelope in a facility regularly maintained by ❑ FEDERAL EXPRESS ❑ UPS ❑ Overnight Delivery [specify name of service: ] with delivery fees fully provided for or delivered the envelope to a courier or driver of ❑ FEDERAL EXPRESS ❑ UPS ❑ OVERNIGHT DELIVERY [specify name of service:] authorized to receive documents at Alston & Bird LLP, 333 South Hope Street, Los Angeles, California 90071 with delivery fees fully provided for. ❑ BY HAND DELIVERY: By giving a true copy(ies) thereof in sealed envelope(s) to ACE Messenger and Attorney Service, Inc. for hand delivery to: (SEE ATTACHED SERVICE LIST) ❑ BY FACSIMILE: I telecopied a copy of said document(s) to the following addressee(s) at the following number(s) in accordance with the written confirmation of counsel in this action. • [State] I declare under penalty of perjury under the laws of the State of California that the above is true and correct. ❑ [Federal] I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on January 10, 2019, at Los Angeles, California. Melinda Jimenez 3 NOTICE OF SETTLEMENT OF ENTIRE CASE AND REQUEST TO CONTINUE CMC Bloxham fdba Cruise Company vs. Orens Universal Inc. dba Plaza Travel Case No. 2026233 SERVICE LIST Mark Nelson Attorneys for Plaintiff Derek Casey Juli Bloxham tbda Cruise Company, Inc. LAW OFFICES OF MARK NELSON 215 McHenry Avenue Modesto, California 95354 Telephone: (209) 529-0995 Facsimile: (209) 529-6207 Email: derek@marksnelson.com 4 NOTICE OF SETTLEMENT OF ENTIRE CASE AND REQUEST TO CONTINUE CMC