Ramirez v. Apena Corp et al

Filing 40

STIPULATION AND ORDER re 39 for Dismissal with Prejudice as to all Defendants filed by Irma Ramirez. Signed by Judge Edward M. Chen on 2/2/17. (bpfS, COURT STAFF) (Filed on 2/2/2017)

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THOMAS E. FRANKOVICH (S.B.N. 074414)
THOMAS E. FRANKOVICH,
A PROFESSIONAL LAW CORPORATION
702 Mangrove Avenue, #304
Chico, CA 95926
Telephone: [phone]
Facsimile:
[phone]
Email:
[e-mail]
Attorney for Plaintiff

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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IRMA RAMIREZ, et al.,

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Plaintiff,

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v.
APENA CORP., et al.,
Defendants.

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) CASE NO. 3:15-cv-03808-EMC
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) STIPULATION OF DISMISSAL AND
) [PROPOSED] ORDER THEREON
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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 Kokkonen v. Guardian Life Ins. Co., 511 U.S. 375
(1994) (empowering the district courts to retain jurisdiction over enforcement of settlement
agreements).

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STIPULATION OF DISMISSAL AND [PROPOSED] ORDER

Respectfully Submitted,

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Dated: January 30, 2017

THOMAS E. FRANKOVICH, APLC

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A PROFESSIONAL LAW CORPORATION

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

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Dated: January 30, 2017

By: /s/ Marvin Pederson
Marvin Pederson
Attorney for Defendant Apena Corp.

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MARVIN PEDERSON, ATTORNEY AT LAW

Dated: January 30, 2017

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VAN DE PEOL, LEVY, ALLEN & ARNEAL, LLP
By: /s/ Nicolet E. Corliss
Nicolet E. Corliss
Attorneys for Defendants Demetrios Giannis and
Rose Giannis

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ORDER

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of enforcing the parties’ Settlement Agreement and General Release should such
enforcement be necessary.

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D

E
ORDER
Hon. IT IS SO
Edward Chen

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UNITED STATES DISTRICT COURT JUDGE
hen

rd M. C

NO

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2/2
Dated: _____________, 2017

UNIT
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IT IS FURTHER ORDERED that the Court shall retain jurisdiction for the purpose

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dwa
Judge E

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Fed.R.Civ.P.41(a)(2) and each side is to bear its own costs and attorneys’ fees.

STIPULATION OF DISMISSAL AND [PROPOSED] ORDER

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IT IS HEREBY ORDERED that this matter is dismissed with prejudice pursuant to

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