Ramirez, et al v. Qoio, et al

Filing 31

STIPULATION AND ORDER OF DISMISSAL. Signed by Magistrate Judge Laurel Beeler on 3/21/2016. (lsS, COURT STAFF) (Filed on 3/21/2016)

1
2
3
4
5
6
7
8

THOMAS E. FRANKOVICH (S.B.N. 074414)
THOMAS E. FRANKOVICH,
A PROFESSIONAL LAW CORPORATION
1832-A Capitol Street
Vallejo, CA 94590
Telephone: [phone]
Facsimile:
[phone]
Email:
[e-mail]
Attorney for Plaintiffs
IRMA RAMIREZ; and
DAREN HEATHERLY

9

UNITED STATES DISTRICT COURT

10

NORTHERN DISTRICT OF CALIFORNIA

11
12

IRMA RAMIREZ; and DAREN
HEATHERLY,

13
14

Plaintiffs,

15

v.

16

QOIO, et al.,

17

Defendants.

18

) CASE NO. 3:14-cv-03243-LB
)
)
) STIPULATION OF DISMISSAL AND
) [PROPOSED] ORDER THEREON
)
)
)
)
)
)
)
)

19
20
21
22
23
24
25
26
27
28

The Parties, by and through their respective counsel, stipulate to dismissal of this
action in its entirety with prejudice pursuant to Fed.R.Civ.P.41(a)(2).
IT IS HEREBY STIPULATED by and between parties to this action through their
designated counsel that the above-captioned action become and hereby is dismissed with
prejudice and each side is to bear its own costs and attorneys’ fees.
The parties further consent to and request that the Court retain jurisdiction over
enforcement of the Agreement. See Kokonen v. Guardian Life Ins. Co., 511 U.S. 375 (1994)
(empowering the district courts to retain jurisdiction over enforcement of settlement
agreements).
STIPULATION OF DISMISSAL AND [PROPOSED] ORDER

1
2

This stipulation may be executed in counterparts, all of which together shall
constitute one original document.
Respectfully Submitted,

3
4

Dated: March 17, 2016

THOMAS E. FRANKOVICH, APLC
A PROFESSIONAL LAW CORPORATION

5
6

By: /s/ Thomas E. Frankovich
Thomas E. Frankovich
Attorney for Plaintiff

7
8
9

Dated: March 17, 2016

MURCHISON & CUMMING, LLP

10

By: /s/ Melissa W. Eisenberg
Melissa W. Eisenberg
Attorney for Defendant Bruno Guarini dba Qoio

11
12
13

Dated: March 17, 2016

ATTORNEY AT LAW

14

By: /s/ Marc Libarle
Marc Libarle
Attorney for Defendant 501 Columbus LLC

15
16
17
18
19
20

ORDER
IT IS HEREBY ORDERED that this matter is dismissed with prejudice pursuant to
Fed.R.Civ.P.41(a)(2) and each side is to bear its own costs and attorneys’ fees. IT IS

21

FURTHER ORDERED that the Court shall retain jurisdiction for the purpose of enforcing

22

the parties’ Settlement Agreement and General Release should such enforcement be

23

necessary.

24

March 21
Dated: _____________, 2016

25
26

Hon. Laurel Beeler
UNITED STATES MAGISTRATE JUDGE

27
28
STIPULATION OF DISMISSAL AND [PROPOSED] ORDER