Opinion
2:19-cv-02102-JCM-EJY
01-27-2023
LEZLIE J. GUNN, an individual, Plaintiff, v. CHRISTINE E. DRAGE, an individual, Defendant.
STIPULATION FOR STAY OF ENFORCEMENT OF JUDGMENT UPON POSTING OF APPELLATE BOND
STIPULATION
Plaintiff Lezlie J. Gunn and defendant Christine E. Drage, by and through their undersigned counsel, enter into the following stipulation with reference to the following:
WHEREAS, judgement was entered in this action in favor of defendant Drage and against plaintiff Gunn on May 1, 2020;
WHEREAS, an amended judgment was entered on March 17, 2021, awarding defendant Drage attorney's fees and costs against plaintiff Gunn;
WHEREAS, the Parties have engaged in discussions regarding plaintiff Gunn's posting a bond to secure the award in the March 17, 2021 amended judgment;
WHEREAS, plaintiff Gunn is making arrangements to post the bond by February 4, 2023;
WHEREAS, the Parties agree that upon posting of the bond in the amount of $401,949.15, proceedings to enforce the judgment will not be necessary pending plaintiff Gunn's appeal to Ninth Circuit Court of Appeals;
WHEREFORE, IT IS HEREBY STIPULATED by and between the Parties, through their respective attorneys of record, that there will be a stay of execution on defendant Drage's judgment against plaintiff Gunn immediately upon the posting of the bond contemplated above, and that the stay will extend until 30-days after the Ninth Circuit Court of Appeals issues its final decision concerning the March 17, 2021 amended judgment.