Beal et al v. Royal Oak Bar et al

Filing 160

STIPULATION AND ORDER FOR DISMISSAL WITH PREJUDICE. Signed by Magistrate Judge Laurel Beeler on 10/25/2016. (lsS, COURT STAFF) (Filed on 10/25/2016)

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1 2 3 4 5 6 STELLA FEY EPLING (SBN 190025) NORTH BEACH LAW 470 Columbus Avenue, Suite 208 P.O. Box 330578 San Francisco, CA 94133 Telephone: 415.433.1448 Attorney for Defendant ROYAL OAK BAR 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 11 12 SAN FRANCISCO DIVISION MICHAEL BEAL and ASHLEY JACKSON, Plaintiffs, 13 14 15 16 Case No. 13-04911 LB JOINT STIPULATION AND [PROPOSED] ORDER FOR DISMISSAL WITH PREJUDICE v. Hon. Laurel Beeler ROYAL OAK BAR and ARES PAPAGEORGE, Defendants. 17 18 COUNTERCLAIM 19 20 21 Pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure, and the Parties’ 22 September 7, 2016 agreement to settle the matter by mutual dismissals and waiving the provisions 23 of California Civil Code section 1542, as agreed in open Court before the Hon. Maria-Elena 24 James, Magistrate Judge, Plaintiffs MICHAEL BEAL and ASHLEY [JACKSON] BEAL, 25 Defendant ARES PAPAGEORGE, and Defendant THE ROYAL OAK BAR, by and through 26 their respective undersigned attorneys and by ARES PAPAGEORGE on his own behalf, hereby 27 submit the following Stipulation for Dismissal with Prejudice. 28 N ORTH B EACH L AW ─ SAN FRA NCI S CO STIPULATION FOR DISMISSAL WITH PREJUDICE 13-04911-LB 1 2 The Parties deny any liability as to the claims and counter-claims asserted against each other. 3 Each side shall bear its own attorneys’ fees and costs. 4 WHEREFORE, the Parties submit to the jurisdiction of this Court to enter an order 5 rescinding the sanctions ordered by the Superior Court of California in the County of San 6 Francisco in this matter on April 17, 2013; and 7 8 9 10 WHEREFORE, the Parties respectfully request this Court to enter an order dismissing the above-captioned matter with prejudice, including all claims, counterclaims and causes of action. IT IS SO STIPULATED. Date: October 20, 2016 NORTH BEACH LAW 11 /s/ Stella Fey Epling 12 Stella Fey Epling, Attorney for Defendant ROYAL OAK BAR 13 14 Date: October 24, 2016 LAW OFFICES OF JOHN BURRIS 15 */s/ DeWitt M. Lacy 16 17 18 Date: October 24, 2016 DeWitt M. Lacy, Attorney for Plaintiffs *Mr. Lacy has given permission for this document to be electronically filed. 19 /s/ Ares Papageorge 20 Defendant Ares Papageorge, in propria persona 21 22 23 24 25 All signers have consented to filing of this document with their conformed signatures. PURSUANT TO STIPULATION, IT IS SO ORDERED. Date: October 25 2016 __, 26 HON. LAUREL BEELER United States Magistrate Judge 27 28 N ORTH B EACH L AW ─ SAN FRA NCI S CO STIPULATION FOR DISMISSAL WITH PREJUDICE -2- 13-04911 LB

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