Hargrove v. City of Bakersfield et al

Filing 104

STIPULATION and ORDER 103 for Waiver of Fees and Costs in Exchange for Waiver of Right to Appeal, signed by Magistrate Judge Jennifer L. Thurston on 10/26/2019. (Hall, S)

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1 2 3 4 5 6 7 8 9 Michael G. Marderosian, No. 77296 Heather S. Cohen, No. 263093 MARDEROSIAN & COHEN 1260 Fulton Street Fresno, CA 93721 Telephone: (559) 441-7991 Facsimile: (559) 441-8170 Virginia Gennaro, No. 138877 City Attorney CITY OF BAKERSFIELD 1501 Truxtun Avenue Bakersfield, CA 93301 Telephone: (661) 326-3721 Facsimile: (661) 852-2020 10 11 Attorneys for: 12 Defendants CITY OF BAKERSFIELD, BAKERSFIELD POLICE DEPARTMENT OFFICER CHRISTOPHER MOORE, BAKERSFIELD POLICE DEPARTMENT SENIOR OFFICER GEORGE VASQUEZ 13 14 UNITED STATES DISTRICT COURT 15 EASTERN DISTRICT OF CALIFORNIA 16 17 TATYANA HARGROVE, 18 Plaintiff, 19 20 vs. 21 22 23 24 CITY OF BAKERSFIELD, BAKERSFIELD POLICE DEPARTMENT OFFICER CHRISTOPHER MOORE, BAKERSFIELD POLICE DEPARTMENT SENIOR OFFICER G. VAZQUEZ, 25 26 Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 1:17-CV-01743-JLT STIPULATION FOR WAIVER OF FEES AND COSTS IN EXCHANGE FOR WAIVER OF RIGHT TO APPEAL AND [PROPOSED] ORDER THEREON 27 28 1 1 Plaintiff TATYANA HARGROVE (“Plaintiff”) and Defendants CITY OF BAKERSFIELD, 2 BAKERSFIELD POLICE DEPARTMENT OFFICER CHRISTOPHER MOORE, and BAKERSFIELD 3 POLICE DEPARTMENT SENIOR OFFICER GEORGE VASQUEZ (“Defendants”), by and through 4 their counsel of record, hereby stipulate to the terms and conditions on this stipulation and jointly request 5 that the court enter its Order at the end of this document. RECITALS 6 WHEREAS, the Court entered Judgment in favor of Defendants and against Plaintiff on October 7 21, 2019. 8 9 10 11 12 WHEREAS, Defendants are entitled to their costs incurred in defense of this action and have agreed to waive those costs in exchange for Plaintiff’s waiver of her right to appeal the Judgment of this case. WHEREAS, Plaintiff has a right to appeal the Court’s Judgment and has agreed to waive her right to appeal in exchange for a waiver of costs and fees by the Defendants. STIPULATION 13 14 15 16 Therefore, the Parties agree as follows: Plaintiff agrees to waive her right to all appealable issues arising in and from this action, including but not limited to the October 21, 2019 Judgment in exchange for Defendants’ waiver of all claims for costs and fees arising from this litigation. 17 18 Dated: October 26, 2019 ALDERLAW, P.C. 19 20 /s/ Neil K. Gehlawat By:________________________________ Neil K. Gehlawat Attorneys for Plaintiff TATYANA HARGROVE 21 22 23 24 Dated: October 26, 2019 THE LAW OFFICE OF THOMAS C. SEABAUGH 25 26 27 28 /s/ Thomas C. Seabaugh By:________________________________ Thomas C. Seabaugh Attorneys for Plaintiff TATYANA HARGROVE 2 1 Dated: October 26, 2019 MARDEROSIAN & COHEN 2 /s/ Michael G. Marderosian By:________________________________ Michael G. Marderosian, Attorneys for Defendants above-named. 3 4 5 6 7 8 9 10 ORDER Upon good cause being shown as set forth in the Stipulation of legal counsel for the Parties, the Court hereby adopts the Stipulation. 11 12 13 14 IT IS SO ORDERED. Dated: October 26, 2019 /s/ Jennifer L. Thurston UNITED STATES MAGISTRATE JUDGE 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3

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