Jones v. City of Orange Cove

Filing 93

STIPULATION and ORDER In Re: Settlement of the Case and Joint Request for Dismissal With Prejudice, signed by Magistrate Judge Dennis L. Beck on 6/25/12. (CASE CLOSED)(Hellings, J)

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H. Ty Kharazi, Esq.; SBN 187894
Nicholas E. Aniotzbehere, Esq.; SBN 263465
YARRA, KHARAZI & ASSOCIATES
1250 Fulton Mall
Fresno, CA 93721
Telephone: [phone]
Facsimile: [phone]
Attorney for Plaintiff,
SUE JONES

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UNITES STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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SUE JONES,
Plaintiff,
vs.

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CITY OF ORANGE COVE.
Defendants.

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Case No: 1:08-cv-00775 LJO DLB
STIPULATION AND ORDER IN RE:
SETTLEMENT OF THE CASE AND JOINT
REQUEST FOR DISMISSAL WITH
PREJUDICE.

Honorable Magistrate Dennis L. Beck, Presiding

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IT IS HEREBY STIPULATED AND AGREED by and between the Plaintiff,

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SUE JONES and Defendant CITY OF ORANGE COVE, by and through their

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respective counsels as follows:

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1. Whereas the parties have reached a full and complete agreement about the
resolution of the dispute between Sue Jones and City of Orange Cove;

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2. Whereas the parties agreement includes a clause for the court to set aside and

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vacate its Order pursuant to stipulation approved by Court on June 29, 2010.

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3. Whereas upon approval of this stipulation the matter shall be completely

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resolved between the parties.

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YARRA, KHARAZI
& ASSOCIATES
1250 Fulton Mall
Fresno, CA 93721

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STIPULATION AND [PROPOSED] ORDER IN RE: DISMISSAL

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The parties respectfully ask the court to:

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1. Vacate all court dates and briefing schedules in this matter.

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2. Incorporate, approve and allow into this Order of Dismissal the parties

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Settlement Agreement and Release (“Settlement Agreement”), a copy of

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which is attached herewith and is incorporated herein by reference as Exhibit

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A.

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3. Vacate the Court’s order pursuant to Stipulation of the Parties dated June 29,
2010.
4. Approve the substitution of the Settlement Agreement (Exhibit A) in lieu of
and instead of the Court’s Order dated June 29, 2010.
5. Dismiss this case and its accompanying Writ of Mandate matter with
prejudice.
6. Each side to pay their own receptive costs and fees in accordance with the
Settlement Agreement and Release.
IT IS SO STIPULATED:

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Dated: June 18, 2012

YARRA, KHARAZI & ASSOCIATES
/s/ H. Ty Kharazi
____________________________________
H. Ty Kharazi, Attorney for Plaintiff,
SUE JONES

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Dated: June 19, 2012

LAW OFFICES OF MICHAEL P. SLATER

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/s/ Michael P. Slater
____________________________________
Michael P. Slater, Attorney for Defendant
CITY OF ORANGE COVE

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YARRA, KHARAZI
& ASSOCIATES
1250 Fulton Mall
Fresno, CA 93721

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STIPULATION AND [PROPOSED] ORDER IN RE: DISMISSAL

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ORDER

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Based on parties Settlement, the former order of this court dated June 29, 2010

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is vacated and this matter is ordered dismissed with prejudice. All future dates and

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briefing schedules are also ordered vacated.

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IT IS SO ORDERED.

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Dated:

/s/ Dennis

June 25, 2012

L. Beck

UNITED STATES MAGISTRATE JUDGE
DEAC_Signature-END:

3b142a

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YARRA, KHARAZI
& ASSOCIATES
1250 Fulton Mall
Fresno, CA 93721

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STIPULATION AND [PROPOSED] ORDER IN RE: DISMISSAL