Ramirez v. Haagsma et al

Filing 22

STIPULATION and ORDER to Dismiss with Prejudice, signed by District Judge Lawrence J. O'Neill on 10/1/14. CASE CLOSED. (Gonzalez, R)

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Daniel K. Klingenberger
#131134
Mark D. Kruthers
#179750
Micah K. Nilsson
#250919
DOWLING AARON INCORPORATED
8080 North Palm Avenue, Third Floor
P.O. Box 28902
Fresno, California 93729-8902
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants LISA HAAGSMA, individually and as a partner in Haagsma & Pinheiro
Dairy, a general partnership; DAVID HAAGSMA, individually and as a partner in Haagsma &
Pinheiro Dairy, a general partnership; and BETTY PINHEIRO, individually, as trustee of the
PINHEIRO FAMILY LIVING TRUST (a partner in Haagsma & Pinheiro Dairy, a general
partnership), and, if and where appropriate, as successor-in-interest for JACK PINHEIRO - deceased
Stanley S. Mallison, Esq.
#184191
Hector R. Martinez, Esq.
#206336
Marco A. Palau, Esq.
#242340
Joseph D. Sutton, Esq.
#269951
MALLISON & MARTINEZ
1939 Harrison Street, Suite 730
Oakland, CA 94612-3547
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiff RAMIRO RAMIREZ

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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RAMIRO RAMIREZ,

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Case No. 1:13-cv-00520-LJO-JLT
Plaintiff,

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vs.

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STIPULATION AND ORDER TO DISMISS
WITH PREJUDICE

LISA HAAGSMA, DAVID HAASGMA,
PINHEIRO FAMILY LIVING TRUST,
BETTY PINHEIRO and JACK PINHEIRO
(dba as “Haagsma & Pinheiro Dairy”),

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Defendants..

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STIPULATION AND ORDER TO DISMISS WITH PREJUDICE

Case No. 1:13-CV-00520-LJO-JLT

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STIPULATION

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THE PARTIES THROUGH THEIR ATTORNEYS OF RECORD HEREBY
STIPULATE AS FOLLOWS:

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1.

The matter has been fully settled and the parties have executed a written settlement

agreement. The agreement calls for this case to be dismissed with prejudice.

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2.

The parties stipulate that this matter be dismissed with prejudice.

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3.

The parties request that the Court retain jurisdiction to enforce the settlement

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agreement.

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IT IS SO STIPULATED
DATED:

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Oct. 1

, 2014
MALLISON & MARTINEZ

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By: /s/ Stan S. Mallison
STAN S. MALLISON
HECTOR R. MARTINEZ
MARCO A. PALAU
JOSEPH D. SUTTON

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Attorneys for Plaintiff,
RAMIRO RAMIREZ

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STIPULATION AND ORDER TO DISMISS WITH PREJUDICE

Case No. 1:13-CV-00520-LJO-JLT

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DATED:

Oct. 1

, 2014

DOWLING AARON INCORPORATED

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By: /s/ Mark D. Kruthers
DANIEL K. KLINGENBERGER
MARK D. KRUTHERS
MICAH K. NILSSON

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Attorneys for Defendants,
LISA HAAGSMA, individually and as a partner in
Haagsma & Pinheiro Dairy, a general partnership;
DAVID HAASGMA, individually and as a partner in
Haagsma & Pinheiro Dairy, a general partnership; and
BETTY PINHEIRO, individually, as trustee of the
PINHEIRO FAMILY LIVING TRUST (a partner in
Haagsma & Pinheiro Dairy, a general partnership), and,
if and where appropriate, as successor-in-interest for
JACK PINHEIRO – deceased

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ORDER

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Based on the stipulation of counsel and good cause shown, this matter is dismissed with

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prejudice. All deadlines are hereby terminated. The parties have reached a settlement through

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counsel. The Court retains jurisdiction to enforce the terms of the settlement agreement. The Court

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hereby directs the clerk to close the file in the above-captioned action. This Order is without waiving

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the ability of any party to move to enforce any provision of the settlement agreement by way of

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separate legal proceedings if a breach of the agreement is alleged.

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SO ORDERED
Dated: October 1, 2014
/s/ Lawrence J. O’Neill
United States District Judge

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STIPULATION AND ORDER TO DISMISS WITH PREJUDICE

Case No. 1:13-CV-00520-LJO-JLT