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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STELLA FEY EPLING (SBN 190025)
[e-mail]
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

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION
MICHAEL BEAL and ASHLEY
JACKSON,
Plaintiffs,

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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.

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COUNTERCLAIM

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Pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure, and the Parties’

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September 7, 2016 agreement to settle the matter by mutual dismissals and waiving the provisions

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of California Civil Code section 1542, as agreed in open Court before the Hon. Maria-Elena

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James, Magistrate Judge, Plaintiffs MICHAEL BEAL and ASHLEY [JACKSON] BEAL,

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Defendant ARES PAPAGEORGE, and Defendant THE ROYAL OAK BAR, by and through

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their respective undersigned attorneys and by ARES PAPAGEORGE on his own behalf, hereby

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submit the following Stipulation for Dismissal with Prejudice.

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N ORTH B EACH
L AW
─
SAN FRA NCI S CO

STIPULATION FOR DISMISSAL WITH PREJUDICE

13-04911-LB

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The Parties deny any liability as to the claims and counter-claims asserted against each
other.

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Each side shall bear its own attorneys’ fees and costs.

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WHEREFORE, the Parties submit to the jurisdiction of this Court to enter an order

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rescinding the sanctions ordered by the Superior Court of California in the County of San

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Francisco in this matter on April 17, 2013; and

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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

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/s/ Stella Fey Epling

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Stella Fey Epling, Attorney for Defendant
ROYAL OAK BAR

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Date: October 24, 2016

LAW OFFICES OF JOHN BURRIS

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*/s/ DeWitt M. Lacy

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Date: October 24, 2016

DeWitt M. Lacy, Attorney for Plaintiffs
*Mr. Lacy has given permission for this
document to be electronically filed.

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/s/ Ares Papageorge

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Defendant Ares Papageorge, in propria persona

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All signers have consented to filing of this document with their conformed signatures.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
Date: October 25 2016
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HON. LAUREL BEELER
United States Magistrate Judge

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N ORTH B EACH
L AW
─
SAN FRA NCI S CO

STIPULATION FOR DISMISSAL WITH PREJUDICE

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13-04911 LB