Fox v. Safe Haven Security Services, Inc.

Filing 8

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr on 9/25/15: This action is dismissed in its entirety with prejudice, each party to bear their own attorneys' fees and costs. (Kaminski, H)

1 POLSINELLI LLP
Charles O. Thompson (SBN 139841)
2 [e-mail]
Garrett Parks (SBN 297971)
3 [e-mail]
Three Embarcadero Center, Suite 1350
4 San Francisco, California 94111
Phone: [phone] │ Fax: [phone]
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Attorneys for Defendant
6 SAFE HAVEN SECURITY SERVICES, INC.
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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10 DENNIS FOX,
Plaintiff,

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Polsinelli LLP
Three Embarcadero Center, Suite 1350
San Francisco, CA 94111
415.248.2100

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vs.

Case No.: 2 :15-cv-01639-MCE-CKD
ORDER AND STIPULATION FOR
DISMISSAL WITH PREJUDICE

13 SAFE HAVEN SECURITY SERVICES,
INC., a corporation; DOES 1 through 20,
14 inclusive,
Defendants.

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Plaintiff Dennis Fox (“Plaintiff”) and Defendant Safe Haven Security Services, Inc. (“Safe

17 Haven”), through their counsel, stipulate and agree as follows:
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1.

On July 22, 2015, Plaintiff filed a complaint for damages against Safe Haven in the

19 Superior Court of California, County of Sacramento, Case No. 34-2015-00182093 (“State Court
20 Complaint”).
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2.

On July 31, 2015, before service, Safe Haven removed the State Court Complaint

22 to this court (collectively, the “Action”).
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3.

On August 20, 2015, the parties participated in mediation to attempt to resolve the

24 Action in its entirety.
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4.

The mediation resulted in the parties resolving the Action and entering into a

26 Confidential Settlement Agreement and General Release of Claims (“Settlement Agreement”).
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5.

The parties agreed to dismiss the Action with prejudice, with each party to bear

28 their own attorneys’ fees and costs.
51353750.1

-1Case No.: 2 :15-cv-01639-MCE-CKD
[PROPOSED] ORDER AND STIPULATION FOR DISMISSAL WITH PREJUDICE

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6.

Plaintiff further agrees that this stipulation will be enforceable in any future action

2 filed against Safe Haven arising out of or relating to the facts supporting the allegations set forth in
3 the Action.
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Counsel for Safe Haven represents that it has the consent of Plaintiff’s counsel to affix its

5 electronic signature to this stipulation on file it on both behalf of the parties.
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Dated: September 24, 2015

POLSINELLI LLP

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By:

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/s/ Charles O. Thompson
CHARLES O. THOMPSON
Attorneys for Defendant Safe Haven
Security Services, Inc.

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Polsinelli LLP
Three Embarcadero Center, Suite 1350
San Francisco, CA 94111
415.248.2100

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Dated: September 24, 2015

LAW OFFICES OF WILLIAM F.
WRIGHT

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By:

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/s/ Julie A. Doumit
JULIE A. DOUMIT
Attorneys for Plaintiff Dennis Fox

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ORDER
Pursuant to the parties Stipulation for Dismissal with Prejudice, the Court hereby orders

20 the above-captioned action dismissed in its entirety with prejudice, each party to bear their own
21 attorneys’ fees and costs. IT IS SO ORDERED.
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Dated: September 25, 2015

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51353750.1

-2Case No.: 2 :15-cv-01639-MCE-CKD
[PROPOSED] ORDER AND STIPULATION FOR DISMISSAL WITH PREJUDICE

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Polsinelli LLP
Three Embarcadero Center, Suite 1350
San Francisco, CA 94111
415.248.2100

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POS: ORDER AND STIPULATION FOR DISMISSAL WITH PREJUDICE
51353750.1