Smith v. G & B Grocers

Filing 16

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr., on 2/6/24 DISMISSING this action with prejudice, as to Plaintiff Maurshae Smith, in its entirety, and without prejudice to the remaining aggrieved employees, if any, as to all claims brought by Plaintiff against all Defendants. CASE CLOSED.(Kastilahn, A)

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Alden J. Parker (SBN 196808)
E-Mail: [e-mail]
Christopher S. Alvarez (SBN 294795)
E-Mail: [e-mail]
FISHER & PHILLIPS LLP
621 Capitol Mall, Suite 1400
Sacramento, California 95814
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
G & B GROCERS dba RANCHO CORDOVA
GROCERY OUTLET [erroneously sued as G & B GROCERS
doing business as Grocery Outlet]

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Anthony J. Nunes (SBN 290224)
Nunes Law Group
15260 Ventura Blvd, Suite 1200
Sherman Oaks, CA 91403
Telephone [phone]
[e-mail]
Attorneys for Plaintiff MAURSHAE SMITH, on behalf of
herself and all others similarly situated

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MAURSHAE SMITH, on behalf of herself and
all others similarly situated,

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Plaintiff,
v.

Case No: 2:21cv-01504-MCE-AC
JOINT STIPULATION FOR DISMISSAL
WITH PREJUDICE OF ALL CLAIMS;
ORDER

G & B GROCERS, a California corporation,
doing business as Grocery Outlet, and DOES 110,

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Defendants.

Complaint Filed: August 22, 2021
Trial Date: None Set

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JOINT STIPULATION FOR DISMISSAL WITH PREJUDICE OF ALL CLAIMS; ORDER
FP 49491520.1

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Plaintiff MAURSHAE SMITH (“Plaintiff”), Defendant G & B GROCERS dba RANCHO

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CORDOVA GROCERY OUTLET [erroneously sued as G & B GROCERS doing business as Grocery

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Outlet] (“Defendant”) (collectively “the Parties”), by and through their counsel of record, hereby

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stipulate under Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure that this entire action be

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dismissed with prejudice.
RECITALS

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WHEREAS, on August 22, 2021, Plaintiff filed the action styled Maushae Smith v. G & B

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GROCERS, a California corporation, doing business as Grocery Outlet, and DOES 1-10, in United

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States District Court Eastern District of California, Case No. 2:21cv-01504-MCE-AC;
WHEREAS, the Parties have agreed to resolve the action through a Settlement Agreement and

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General Release, fully executed on November 16, 2023 (the “Agreement”); and
WHEREAS, the Parties seek dismissal of this entire action and all claims with prejudice to

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comply with the Agreement.
STIPULATION

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NOW THEREFORE, IT IS HEREBY STIPULATED by the Parties, pursuant to Rule

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41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure, as follows:
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The action, and all claims therein, is dismissed with prejudice as to Plaintiff Maurshae

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Smith, in its entirety, and without prejudice to the remaining aggrieved employees, if any; and

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JOINT STIPULATION FOR DISMISSAL WITH PREJUDICE OF ALL CLAIMS; ORDER
FP 49491520.1

Each party shall bear its and/or her own respective attorneys’ fees and costs.

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2.

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IT IS SO STIPULATED.

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Dated: February 5, 2024

FISHER & PHILLIPS LLP

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By: /s/ Christopher S. Alvarez
Alden J. Parker
Christopher S. Alvarez

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Attorneys for Defendant
G & B GROCERS dba RANCHO CORDOVA
GROCERY OUTLET [erroneously sued as
G & B GROCERS doing business as
Grocery Outlet]

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DATE: February 5, 2024

NUNES WORKER RIGHTS LAW, APC

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By: /s/ Anthony J. Nunes [as authorized on 2.5.24]
Anthony J. Nunes

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Attorneys for Plaintiff
MAURSHAE SMITH

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JOINT STIPULATION FOR DISMISSAL WITH PREJUDICE OF ALL CLAIMS; ORDER
FP 49491520.1

ORDER

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Pursuant to stipulation of the Parties, and for good cause shown, the above-captioned

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action shall be dismissed with prejudice, as to Plaintiff Maurshae Smith, in its entirety, and without

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prejudice to the remaining aggrieved employees, if any, as to all claims brought by Plaintiff against all

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Defendants.

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IT IS SO ORDERED.
Dated: February 6, 2024

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JOINT STIPULATION FOR DISMISSAL WITH PREJUDICE OF ALL CLAIMS; ORDER
FP 49491520.1