JOINT STIPULATION RE UNDISPUTED FACTS 

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STEPHEN L. DAVIS (State Bar No. 149817) 

DAVIS & LEONARD, LLP

8880 Cal Center Drive 

Suite 180 

Sacramento, California 95826 

Telephone: (916) 362-9000 

Fax: (916) 362-9066 

E-mail: sdavis@davisandleonard.com

Attorneys for Plaintiff 

Keith Stafford 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

KEITH STAFFORD, an individual, 

 Plaintiff, 

v. 

UNITED TREASURES, INC., a Washington 

corporation, 

 Defendant. 

CASE NO. CIV S-04-0047 FEB PAN 

JOINT STIPULATION BY PARTIES TO 

ADDITIONAL UNDISPUTED FACTS 

CONCERNING CORRESPONDENCE; 

REQUEST TO ADD TO CURRENT 

UNDISPUTED FACTS; PROPOSED 

ORDER ON STIPULATION 

Trial: 

Date: October 4th, 2005 

Time: 9 a.m. 

Courtroom: 10 

Plaintiff Keith Stafford, through his counsel Stephen L. Davis of Davis & Leonard 

LLP, and defendant United Treasures, Inc., through its counsel Ropers Majeski Kohn & 

Bentley, hereby submit this stipulation to additional undisputed facts for the trial in this 

matter. 

The parties hereby stipulate that the undisputed facts set forth below as paragraphs 

1 through 7 should be added to the undisputed facts set forth in section II of the final 

pretrial order, and that they should be accepted as undisputed for purposes of trial and may 

be read by either of the parties to the jury as provided in the final pretrial order. 

Case 2:04-cv-00047-GEB-EFB Document 140 Filed 09/22/05 Page 1 of 3
 

JOINT STIPULATION RE UNDISPUTED FACTS 

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The parties further request, in the interest of justice and in the interest of avoiding 

unnecessary consumption of the court’s time and the jury’s time, that the court grant this 

stipulation and allow these undisputed facts to be added to the undisputed facts contained 

in section II of the final pretrial order dated June 21, 2005. 

1. Ronald St. Marie and Thomas Chan are attorneys with the law firm of the 

Chan Law Group and have represented the defendant United Treasures, Inc. as its 

attorneys since at least December 1, 2003. 

2. Stephen L. Davis is an attorney with the law firm of Davis & Leonard LLP 

and has represented the plaintiff Keith Stafford as his attorney since at least December 12, 

2003. 

3. Keith Stafford’s attorney, Stephen L. Davis, sent the letter marked as 

Plaintiff’s Exhibit 93 in the mail on or about December 12, 2003 to the Chan Law Group, 

and this letter was received in the mail by the Chan Law Group. 

4. United Treasures, Inc.’s attorney, Ronald St. Marie, sent the letter marked 

as Plaintiff’s Exhibit 94 in the mail on or about December 15, 2003 to Stephen L. Davis, 

and this letter was received in the mail by Stephen L. Davis. 

5. Keith Stafford’s attorney, Stephen L. Davis, sent the letter marked as 

Plaintiff’s Exhibit 104 in the mail on or about January 8, 2004 to Thomas Chan of the 

Chan Law Group, and this letter was received in the mail by Thomas Chan. 

6. United Treasures, Inc.’s attorney, Ronald St. Marie, sent the letter marked 

as Plaintiff’s Exhibit 105 in the mail on or about January 28, 2004 to Stephen L. Davis, 

and this letter was received in the mail by Stephen L. Davis. 

5. Keith Stafford’s attorney, Stephen L. Davis, sent the letter marked as 

Plaintiff’s Exhibit 106 in the mail on or about January 29, 2004 to Ronald St. Marie of the 

Chan Law Group, and this letter was received in the mail by Ronald St. Marie. 

6. Keith Stafford’s attorney, Stephen L. Davis, sent the letter marked as 

Plaintiff’s Exhibit 110 in the mail on or about August 16, 2004 to Ronald St. Marie of the 

Chan Law Group, and this letter was received in the mail by Ronald St. Marie. 

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JOINT STIPULATION RE UNDISPUTED FACTS 

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7. United Treasures, Inc.’s attorney, Ronald St. Marie, sent the letter marked 

as Plaintiff’s Exhibit 111 in the mail on or about September 9, 2004 to Stephen L. Davis, 

and this letter was received in the mail by Stephen L. Davis. 

SO STIPULATED. 

Dated: August 24, 2005. 

DAVIS & LEONARD, LLP 

/s/_Stephen L. Davis___________

Stephen L. Davis 

Attorneys for Plaintiff Keith Stafford

Dated: August 24, 2005. 

ROPERS, MAJESKI, KOHN, & BENTLEY 

/s/_Elise Vasquez______________

Elise Vasquez 

Attorneys for Defendant United 

Treasures, Inc. 

ORDER

IT IS ORDERED THAT this stipulation is approved and the facts set forth in 

paragraphs 1 through 7 shall be deemed undisputed for trial and may be read to the jury as 

set forth in the final pretrial order dated June 21, 2005. 

DATED: September 22, 2005 

 /s/ Garland E. Burrell, Jr. 

 GARLAND E. BURRELL, JR. 

United States District Judge 

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