Predmore v. Stockton Enterprises, LLC et al

Filing 37

ORDER signed by District Judge Morrison C. England, Jr. on 10/28/2019 ORDERING Plaintiff's claims are DISMISSED with prejudice, and the Clerk of the Court is directed to close this case. CASE CLOSED (Reader, L)

1 STAN S. MALLISON (Bar No. 184191)
[e-mail]
2 HECTOR R. MARTINEZ (Bar No. 206336)
[e-mail]
3 NATALIA RAMIREZ LEE (Bar. No. 322017)
[e-mail]
4 MALLISON & MARTINEZ
1939 Harrison Street, Suite 730
5 Oakland, California 94612-3547
Telephone: [phone]
6 Facsimile: [phone]
7 Attorneys for Plaintiff
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Case No: 17-cv-01091-MCE-GGH
12 JULIA PREDMORE individually and
acting in the interest of other current and
STIPULATION TO DISMISS
13 former employees and the public,
CLAIMS; ORDER
Plaintiff,
Cal. Cod
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vs.

Before the Hon. Morrison C. England Jr.

STOCKTON ENTERPRISES, LLC, a
Limited Liability Company; DÉJÀ VU
SHOWGIRLS-SACRAMENTO, LLC, a
Limited Liability Company; and DOES
1-20, inclusive,
Defendants.

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Stipulation and Order to Dismiss with Prejudice

Case No. 17-cv-01091-MCE-GGH

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Plaintiff Julia Predmore (“Plaintiff”), and Defendants Stockton Enterprises, LLC and Déjà

2 vu Showgirls – Sacramento, LLC (“Defendants”), collectively the “Parties,” through their
3 respective counsel, hereby stipulate as follows:
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RECITALS

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1. Parties have reached settlement in this case.

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2. Parties have agreed to dismiss with prejudice all claims asserted by Plaintiff in this matter

7 including: (1) failure to pay the Federal minimum wage, (2) failure to pay for all hours worked, (3)
8 failure to pay the State minimum wage, (4) failure to pay overtime compensation, (5) failure to
9 provide meal periods, (6) failure to provide rest periods, (7) unlawful deductions and kickback
10 payments, (8) failure to provide accurate wage statements, (9) failure to timely pay wages due at
11 termination, (10) failure to indemnify employees for work expenses.
12 THEREFORE, it is hereby stipulated, by and between the Parties and their counsel of record, that:
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A.

Plaintiff’s claims are dismissed with prejudice, and the Parties shall bear their

14 respective fees and costs, with Defendant waiving any right to costs or fees.
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Respectfully submitted,
Date: October 17, 2019

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MALLISON & MARTINEZ

By: _/S/ Stan S. Mallison

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Stan S. Mallison
Attorneys for Plaintiff

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LONG & LEVIT LLP

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By: __/S/ Shane M. Cahill

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Shane M. Cahill
Attorneys for Defendants

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Stipulation and Order to Dismiss with Prejudice

Case No. 17-cv-01091-MCE-GGH

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ORDER
Pursuant to stipulation and for good cause shown, Plaintiff’s claims are dismissed with

3 prejudice, and the Clerk of the Court is directed to close this case.
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IT IS SO ORDERED.

5 Dated: October 28, 2019
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Stipulation and Order to Dismiss with Prejudice

Case No. 17-cv-01091-MCE-GGH