Amy N. Nguyen v. Volkswagen Group of America, Inc. et al

Filing 53

JUDGMENT PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 68 by Judge Hernan D. Vera, in favor of Amy N. Nguyen against Volkswagen Group of America, Inc.: 1. Defendant will pay Plaintiff $65,212.85 to resolve Plaintiff's claims related to the purchase, servicing, and warranties of the 2019 Audi E-Tron, VIN WA1VABGE3KB016016 in this action. (see document for further details) Related to: Notice 52 (MD JS-6, Case Terminated). (bm)

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

JS-6

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4 AMY N. NGUYEN, an individual,

Plaintiff,

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v.

7 VOLKSWAGEN GROUP OF

AMERICA, INC, and DOES 1

8 through 10, inclusive,
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Defendants.

Case No. 2:23-cv-04104-HDV-JC
Assigned for all purposes to the Hon.
Hernán D. Vera in Dept. 5B
[PROPOSED] JUDGMENT PURSUANT
TO FEDERAL RULE OF CIVIL
PROCEDURE 68
Action Filed:
Trial Date:

April 19, 2023
October 15, 2024

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14 TO THE COURT, ALL PARTIES, AND TO THEIR ATTORNEYS OF
15 RECORD:
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Plaintiff Amy N. Nguyen (“Plaintiff”), submits the following Proposed

17 Judgment, following Defendant Volkswagen Group of America, Inc.’s (“Defendant”)
18 acceptance of Plaintiff’s Offer of Judgment pursuant to Rule 68 of the Federal Rules
19 of Civil Procedure:
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1. Defendant will pay Plaintiff $65,212.85 to resolve Plaintiff’s claims related

21 to the purchase, servicing, and warranties of the 2019 Audi E-Tron, VIN
22 WA1VABGE3KB016016 in this action.
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2. Defendant will also pay Plaintiff’s attorney’s fees, expenses, and costs

24 pursuant to California Civil Code §1794(d) in an amount to be determined by the Court
25 via a single noticed motion. Defendant agrees that Plaintiff is the prevailing party in
26 this action. Defendant shall pay the attorneys’ fees and cost amounts determined by the
27 Court within 30 days’ notice of the Court’s ruling on same.
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3. Apart from the amounts set forth above, each side agrees to bear its own
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[PROPOSED] JUDGMENT PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 68

1 attorney’s fees and costs.
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4. The amount set forth in Paragraph 1 shall be paid to Plaintiff within thirty

3 (“30”) days of acceptance of this offer of judgment.
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5. Plaintiff will stipulate to dismiss the Complaint with prejudice within 5

5 business days after receiving all payments from Defendant due to Plaintiff and her
6 counsel.
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6. The parties hereby stipulate that the Court shall retain jurisdiction to enforce

8 this offer of judgment.
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12 Dated: 8/29/24

__________________________________
__________________________

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Honorable Judge Hernán D. Vera
Judge for the Central District of California

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[PROPOSED] JUDGMENT PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 68

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CERTIFICATE OF SERVICE

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I hereby certify that on August 28, 2024, I filed the foregoing document entitled

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[PROPOSED] JUDGMENT PURSUANT TO FEDERAL RULE OF CIVIL

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PROCEDURE 68 with the clerk of court using the CM/ECF system, which will

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send a notice of electronic filing to all counsel of record in this action.

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/s/ Jasmine Aragon
______________________________
Jasmine Aragon

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CERTIFICATE OF SERVICE