1 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

CALLIDUS CAPITAL CORPORATION, 

 Plaintiff, 

 Case No. 2:15-cv-10616 

v. Hon. Robert H. Cleland 

 Mag. Judge Elizabeth A. Stafford 

HARVEY INDUSTRIES LLC, et al., 

 Defendants. 

 

STIPULATION FOR ENTRY OF ORDER 

TERMINATING RECEIVERSHIP, DISCHARGING 

RECEIVER, AND FOR OTHER RELIEF

 By the signatures of their counsel below, Callidus Capital Corporation, the 

Plaintiff herein, Harvey Industries LLC and Harvey Property Management LLC, 

the Defendants herein, stipulate to the entry of the Order Terminating 

Receivership, Discharging Receiver, and For Other Relief, attached hereto as 

Exhibit “A.” 

Stipulated and Agreed:

CALLIDUS CAPITAL CORPORATION

By: /s/ Matthew Hammer (w/consent) 

Michael C. Hammer (P41705) 

Doron Yitzchaki (P72044) 

Dickinson Wright PLLC 

350 S. Main Street, Suite 300 

Ann Arbor, MI 48104 

734-623-7075 

mchammer2@dickinsonwright.com 

HARVEY INDUSTRIES LLC AND HARVEY 

PROPERTY MANAGEMENT LLC 

By: /s/ Joseph Fischer (w/consent) 

Joseph M. Fischer (P13452) 

Carson Fischer, P.L.C. 

4111 Andover Road West, Second Floor 

Bloomfield Hills, MI 48302-1924 

248-644-4840 

jfischer@carsonfischer.com 

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Attorney for Plaintiff 

STEVEN R. WYBO

By: /s/ Matthew E. Wilkins 

Matthew E. Wilkins (P56697) 

Daniel N. Sharkey (P53837) 

Brooks Wilkins Sharkey & Turco, PLLC 

401 S. Old Woodward Avenue, Suite 400 

Birmingham, MI 48009 

(248) 971-1711 

wilkins@bwst-law.com 

sharkey@bwst-law.com 

Attorneys for Receiver 

Attorney for Defendants 

Dated: March 17, 2016 

 

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UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

CALLIDUS CAPITAL CORPORATION, 

 Plaintiff, 

 Case No. 2:15-cv-10616 

v. Hon. Robert H. Cleland 

 Mag. Judge Elizabeth A. Stafford 

HARVEY INDUSTRIES LLC, et al., 

 Defendants. 

 

ORDER TERMINATING RECEIVERSHIP 

AND DISCHARGING RECEIVER

 Steven R. Wybo, the appointed Receiver herein (the “Receiver”) has filed 

the Receiver’s Motion for Order Terminating Receivership, Discharging Receiver, 

and for Other Relief (the “Motion”).1

 Having read and considered the Motion, any 

timely filed objections, and other relevant pleadings in this action, the Court finds 

that good cause exists for the granting of the relief requested in the Motion. 

Accordingly, the Motion is granted, and it is ORDERED THAT: 

 A. The receivership over Defendants Harvey Industries LLC and Harvey 

Property Management is terminated. 

 B. The Receiver and all professionals employed by him are discharged of 

their duties and are released from all claims and causes of action of any kind and 

 

1

 Capitalized terms not otherwise defined herein have the meanings ascribed to them in the 

Motion. 

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nature arising from or relating to their duties and services rendered in this 

receivership. 

 C. All persons and entities which may have held, or which currently 

hold, claims against the Defendants and/or the assets of Defendants are forever 

barred, estopped and permanently enjoined from asserting, prosecuting or 

otherwise pursuing such claims (i) against the Receiver, the Receivership Estate 

and the Purchasers, and (ii) against the assets of the Receiver, the Receivership 

Estate and the Purchasers. 

 D. This Court shall retain jurisdiction over any and all matters relating to 

the receivership. 

 S/Robert H. Cleland 

 ROBERT H. CLELAND 

 UNITED STATES DISTRICT JUDGE 

Dated: March 29, 2016 

I hereby certify that a copy of the foregoing document was mailed to counsel of record 

and/or pro se parties on this date, March 29, 2016, by electronic and/or ordinary mail. 

 S/Lisa Wagner 

 Case Manager and Deputy Clerk 

 (313) 234-5522 

 

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