Ramirez v. 101 Smith Ranch Road Strip Mall et al

Filing 17

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

1
2
3
4
5
6
7

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 Plaintiff
IRMA RAMIREZ

8
9

UNITED STATES DISTRICT COURT

10

NORTHERN DISTRICT OF CALIFORNIA

11
12

IRMA RAMIREZ,

13
14

Plaintiff,
v.

15
16
17
18
19
20

101 SMITH RANCH ROAD STRIP
MALL, et al.,
Defendants.

) CASE NO. 3:15-cv-02578-LB
)
)
) STIPULATION OF DISMISSAL AND
) [PROPOSED] ORDER THEREON
)
)
)
)
)
)
)
)
)
)
)
)

21
22
23
24
25
26

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.

27
28
STIPULATION OF DISMISSAL AND [PROPOSED] ORDER

1

The parties further consent to and request that the Court retain jurisdiction over

2

enforcement of the Agreement. See Kokonen v. Guardian Life Ins. Co., 511 U.S. 375 (1994)

3

(empowering the district courts to retain jurisdiction over enforcement of settlement

4

agreements).

5
6

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

7
8

Dated: March 2, 2016

THOMAS E. FRANKOVICH, APLC
A PROFESSIONAL LAW CORPORATION

9
10

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

11
12
13

Dated: March 2, 2016

BRADLEY, CURLEY, ASIANO, BARRABEE,
ABEL & KOWALSKI, P.C.

14
By: /s/ Sara Allman
Sara Allman
Attorney for Defendants

15
16
17

ORDER

18
19
20
21
22
23
24
25
26
27

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
FURTHER ORDERED that the Court shall retain jurisdiction for the purpose of enforcing
the parties’ Settlement Agreement and General Release should such enforcement be
necessary.
March 3
Dated: _____________, 2016

Hon. Laurel Beeler
UNITED STATES MAGISTRATE JUDGE

28
STIPULATION OF DISMISSAL AND [PROPOSED] ORDER