Proeung v. Maximus, Inc.

Filing 23

ORDER signed by Magistrate Judge Kendall J. Newman on 3/16/15 re: 22 DISMISSING CASE WITH PREJUDICE, in its entirety. Each party to this action shall bear its own attorneys' fees and costs of suit. CASE CLOSED. (Meuleman, A)

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DAVID P. FOOS (SBN: 083430)
FOOS | GAVIN LAW FIRM, P.C.
3947 Lennane Drive, Suite 120
Sacramento, CA 95834
T: 916.779.3500
F: 916.779.3508
E: [e-mail]
Attorney for Plaintiff,
SAMBATH PROEUNG

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JEREMY A. MEIER - SBN 139849
JENNIFER M. HOLLY - SBN 263705
GREENBERG TRAURIG, LLP
1201 K Street, Suite 1100
Sacramento, CA 95814-3938
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for Defendant,
MAXIMUS, Inc.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SAMBATH PROEUNG,

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Plaintiff,
v.

Case No.: 2:14-cv-00063-MCE-KJN
JOINT STIPULATION FOR DISMISSAL
WITH PREJUDICE, PURSUANT TO
F.R.C.P. RULE 41(a)(1); AND [PROPOSED]
ORDER

MAXIMUS, INC., a California
Corporation, and DOES 1 through
50, inclusive,
Defendants.

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WHEREAS Plaintiff SAMBATH PROEUNG and Defendant MAXIMUS, INC. agree that
all claims in the above-captioned proceeding have been fully settled and compromised;
IT IS HEREBY STIPULATED by and between the parties to this action, through their

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undersigned counsel, that the above-captioned action be and hereby is dismissed with prejudice

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as to Defendant MAXIMUS, INC. pursuant to F.R.C.P. 41(a)(1);

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Proeung v. MAXIMUS, Inc.
JOINT STIPULATION OF DISMISSAL WITH PREJUDICE, PURSUANT
TO F.R.C.P. RULE 41(a)(1); AND PROPOSED ORDER

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IT IS FURTHER STIPULATED by and between the parties that each party shall bear its
own attorneys’ fee and costs of suit.
IT IS FURTHER STIPULATED by and between the parties that the parties mutually

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and fully release and forever discharge each other and their agents from any and all actions,

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suits, demands, debts, expenses, accounts, reckonings, obligations, costs, rights, agreements,

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promises, liabilities, liens, damages, or causes of action that may stem from any of the facts or

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causes of actions alleged in this lawsuit including, but not limited to, any and all claims known

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or unknown, including any common law claims, debts, liabilities, demands, damages, charges,

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promises, acts, agreements, claims for negligence, costs and expenses (including any claim for

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attorneys' fees), actions and causes of action, or any claim for violation of civil rights or of any

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other state or federal statute or constitution. This release extends to the parties SAMBATH

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PROEUNG and MAXIMUS, INC. in all capacities.

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Date: March 13, 2015

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Respectfully Submitted,
FOOS GAVIN LAW FIRM, P.C.

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By: ___/s/ David P. Foos______________________
David P. Foos (SBN: 083430)
Attorney for Plaintiff, SAMBATH PROEUNG

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Date: March 13, 2015

Respectfully Submitted,

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GREENBURG TRAURIG, LLP

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By: /s/ Jeremy A. Meier
Jeremy A. Meier (SBN: 139849)

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By: /s/ Jennifer M. Holly
Jennifer M. Holly (SBN: 167533)

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Attorneys for Defendant, MAXIMUS, INC.

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Proeung v. MAXIMUS, Inc.
JOINT STIPULATION OF DISMISSAL WITH PREJUDICE, PURSUANT
TO F.R.C.P. RULE 41(a)(1); AND PROPOSED ORDER

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[PROPOSED] ORDER
In view of the parties’ Stipulation, the Court orders the above-captioned action be

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dismissed with prejudice, in its entirety. Each party to this action shall bear its own attorneys’

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fees and costs of suit.

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IT IS SO ORDERED.
Dated: March 16, 2015

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Proeung v. MAXIMUS, Inc.
JOINT STIPULATION OF DISMISSAL WITH PREJUDICE, PURSUANT
TO F.R.C.P. RULE 41(a)(1); AND PROPOSED ORDER

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