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TIMOTHY S. THIMESCH, Esq. (No. 148213) 

GENE FARBER, Esq. (No. 44215) – Of Counsel 

171 Front Street, Suite 102 

Danville, CA 94526-3321 

Direct: (925) 855-8235 

Plaintiffs LARRY McIVER, HOLLYNN D’LIL, ISC, INC., 

RUSS BOHLKE, CHRISTINE FITZGERALD, 

CONNIE ARNOLD, and JEFFREY EVANS 

STEPHEN E. HORAN, ESQ. (No. 125241) 

PORTER, SCOTT, WEIBERG & DELEHANT 

350 University Avenue, Suite 200 

Post Office Box 255428 

Sacramento, CA 95865 

Tel: 916/929-1481 

Attorneys for defendant CALIFORNIA EXPOSITION 

& STATE FAIR 

CARYN L. CRAIG, ESQ., No. 185621 

OFFICE OF THE ATTORNEY GENERAL 

P.O. Box 944255 

Sacramento, CA 94244-2550 

Fax No. 916/327-2319 

Attorneys for defendant STATE OF CALIFORNIA 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

LARRY McIVER, HOLLYNN D’LIL, ISC, INC., 

RUSS BOHLKE, CHRISTINE FITZGERALD, 

CONNIE ARNOLD, and JEFFREY EVANS, 

Plaintiffs, 

v. 

THE CALIFORNIA EXPOSITION & 

FAIR, aka “Cal Expo”; STATE OF CALIFORNIA; 

RAY CAMMACK SHOWS, INC.; and DOES 2-

5000, Inclusive, 

Defendants. 

Case No. S-2:01-1967 KJM 

[Consolidated Case No. 04-1790 KJM] 

 

STIPULATION AND ORDER RE 

DISMISSAL OF ATTORNEYS’ FEES 

AND COSTS CLAIMS AS TO 

DEFENDANT CAL EXPO 

TO THE COURT: Plaintiffs LARRY McIVER, HOLLYNN D’LIL, 

ISC, INC., RUSS BOHLKE, CHRISTINE FITZGERALD, CONNIE ARNOLD, and 

JEFFREY EVANS and Defendants CALIFORNIA EXPOSITION AND STATE FAIR and 

STATE OF CALIFORNIA hereby stipulate that they have reached a complete and good faith 

settlement of Plaintiffs’ remaining claim for reasonable statutory attorney fees, litigation 

expenses and costs against said Defendants, which the stipulating parties request that the 

Court dismiss with prejudice. The settlement was reached thanks to the efforts of Honorable 

Dale A. Drozd at settlement conference. 

This request is limited to Defendants CALIFORNIA EXPOSITION AND STATE 

FAIR and STATE OF CALIFORNIA and the claim for fees, but neither affects Plaintiffs’ 

Case 2:04-cv-01790-KJM Document 31 Filed 05/02/06 Page 1 of 2
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remaining claim for attorney fees, litigation expenses and costs against Defendant RAY 

CAMMACK SHOWS, INC., which remains pending before the Court, nor the Consent 

Judgments entered by the Court on December 16, 2005. 

SO STIPULATED: 

DATED: May 1, 2006 THIMESCH LAW OFFICES

TIMOTHY S. THIMESCH 

 

By Attorneys for Plaintiffs 

LARRY McIVER, HOLLYNN D’LIL, 

ISC, INC., RUSS BOHLKE, CHRISTINE 

FITZGERALD, CONNIE ARNOLD, and JEFFREY 

EVANS 

Dated: , 2006 STEPHEN E. HORAN, ESQ. 

JEFFREY CHRISTENSEN, ESQ. 

PORTER, SCOTT, WEIBERG & DELEHANT 

 

1

Attorneys for Defendant 

CALIFORNIA EXPOSITION & STATE FAIR 

Dated: , 2006 CARYN CRAIG, ESQ. 

OFFICE OF THE ATTORNEY GENERAL 

OF THE STATE OF CALIFORNIA 

 

Attorneys for Defendant 

STATE OF CALIFORNIA 

●●●

ORDER

The Court approves the foregoing stipulation. Plaintiffs’ motion for attorneys’ fees and 

costs as to defendant Cal Expo is dismissed with prejudice. IT IS SO ORDERED. 

Dated: May 1, 2006. 

_____________________________________ 

UNITED STATES MAGISTRATE JUDGE 

 

1 The court acknowledges receipt of an original stipulation signed by both defense counsel. 

Case 2:04-cv-01790-KJM Document 31 Filed 05/02/06 Page 2 of 2