Floyd v. Saber Fitness Hegenberger, LLC

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Joint Stipulation and [Proposed] Injunction Case No. 3:24-cv-01278-TSH
Michael Devin Floyd
2323 Broadway
Oakland, CA 94612
E-mail: Mdf3039@gmail.com
Telephone: (713) 562-7229
Michael Devin Floyd, IN PRO PER
Ronald Q. Tran (294873)
Liam N. Gaarder-Feingold (345747)
JACKSON LEWIS P.C.
50 California Street, 9th Floor
San Francisco, California 94111-4615
Telephone: (415) 394-9400
Facsimile: (415) 394-9401
E-mail: Ronald.Tran@jacksonlewis.com
Liam.gaarderfeingold@jacksonlewis.com
Attorneys for Defendant
SABER FITNESS HEGENBERGER, LLC
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO DIVISION
Michael Devin Floyd
Plaintiff(s),
v.
Saber Fitness Hegenberger, LLC
27 Northwestern Drive Suite 2
Salem, NH 03079
Defendant(s).
Case No. 3:24-cv-01278-TSH
STIPULATION AND [PROPOSED]
INJUNCTION
Removal Filed: 03/01/2025
Trial Date: 1/12/2026
Case 3:24-cv-01278-TSH Document 182 Filed 12/22/25 Page 1 of 4

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Joint Stipulation and [Proposed] Injunction Case No. 3:24-cv-01278-TSH
WHEREAS, Plaintiff Michael Devin Floyd (“Plaintiff”) and Defendant Saber Fitness
Hegenberger, LLC (“Defendant”) (collectively the “Parties”) settled the instant action and
memorialized the core terms and conditions of the settlement agreement on the record on
November 24, 2025. ECF 175.
WHEREAS, a material term of the settlement agreement included entering into a stipulated
injunction (the “Injunction”) and making a joint request to the Court for entry of the Injunction.
THEREFORE, the Parties expressly agree to the following terms of the Injunction:
The Injunction will enjoin, prohibit, and otherwise forbid Plaintiff, for a term of ten (10)
years, from entering, using, applying for, or otherwise entering into a membership agreement with,
any and all Planet Fitness gyms owned or operated by Defendant, Taymax Group, L.P., and its
affiliated entities, including any past, present, and future direct or indirect parent organizations,
subsidiaries, divisions, successors, and assigns (collectively referred to herein as “Taymax
Entities”).
The Injunction applies to any Planet Fitness gyms acquired by the Taymax Entities at any
point during the ten (10) year Injunction.
Taymax Group, L.P. and all Taymax Entities identified herein are express and intended
third party beneficiaries of this Injunction.
The Court shall retain jurisdiction for purposes of enforcement of the Parties’ Injunction,
which includes the power to issue any lawful order it deems proper to enforce the injunction,
including, but not limited to, exercising its discretion to find the breaching party in contempt per
18 U.S.C. 401.
Dated: December 19, 2025 JACKSON LEWIS P.C.
By: /s/
Ronald Q. Tran
Attorneys for Defendant
SABER FITNESS HEGENBERGER, LLC
Dated: December 20, 2025
Case 3:24-cv-01278-TSH Document 182 Filed 12/22/25 Page 2 of 4

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Joint Stipulation and [Proposed] Injunction Case No. 3:24-cv-01278-TSH
By: /s/
Michael Devin Floyd
Plaintiff, IN PRO PER
DECLARATION
Pursuant to Local Rule 5-1(i)(3), I attest that Plaintiff Michael Devin Floyd has concurred
in the filing of this document, the concurrence of which shall serve in lieu of Plaintiff’s signature
on the document.
Dated: December 20, 2025 JACKSON LEWIS P.C.
By: /s/
Ronald Q. Tran
Liam Feingold Gaarder
Attorneys for Defendant
SABER FITNESS HEGENBERGER, LLC
Case 3:24-cv-01278-TSH Document 182 Filed 12/22/25 Page 3 of 4

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Joint Stipulation and [Proposed] Injunction Case No. 3:24-cv-01278-TSH
[PROPOSED] INJUNCTION
Based on the foregoing, and good cause appearing, the Court approves of the Parties’
Stipulated Injunction and hereby makes the following Order:
The Injunction will enjoin, prohibit, and otherwise forbid Plaintiff, for a term of ten (10)
years, from entering, using, applying for, or otherwise entering into a membership agreement with,
any and all Planet Fitness gyms owned or operated by Defendant, Taymax Group, L.P., and its
affiliated entities, including any past, present, and future direct or indirect parent organizations,
subsidiaries, divisions, successors, and assigns (collectively referred to herein as “Taymax
Entities”).
The Injunction applies to any Planet Fitness gym acquired by the Taymax Entities at any
point during the ten (10) year Injunction.
All Taymax Entities identified herein are express and intended third party beneficiaries of
this Injunction.
The Court shall retain jurisdiction for purposes of enforcement of the Parties’ Injunction,
which includes the power to issue any lawful order it deems proper to enforce the injunction,
including, but not limited to, exercising its discretion to find the breaching party in contempt per
18 U.S.C. 401.
IT IS SO ORDERED.
Dated: December 22, 2025 By:
HON. THOMAS S. HIXSON
United States Magistrate Judge
Case 3:24-cv-01278-TSH Document 182 Filed 12/22/25 Page 4 of 4