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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1 2 3 4 5 6 7 THOMAS E. FRANKOVICH (S.B.N. 074414) THOMAS E. FRANKOVICH, A PROFESSIONAL LAW CORPORATION 702 Mangrove Avenue, #304 Chico, CA 95926 Telephone: (415) 444-5800 Facsimile: (415) 674-9900 Email: tfrankovich@disabilitieslaw.com Attorney for Plaintiff 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 11 IRMA RAMIREZ, et al., 12 Plaintiff, 13 14 15 v. APENA CORP., et al., Defendants. 16 17 ) CASE NO. 3:15-cv-03808-EMC ) ) ) STIPULATION OF DISMISSAL AND ) [PROPOSED] ORDER THEREON ) ) ) ) ) ) ) 18 19 20 21 22 23 24 25 26 27 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). 28 STIPULATION OF DISMISSAL AND [PROPOSED] ORDER Respectfully Submitted, 1 2 3 Dated: January 30, 2017 THOMAS E. FRANKOVICH, APLC 4 A PROFESSIONAL LAW CORPORATION 5 By: /s/ Thomas E. Frankovich Thomas E. Frankovich Attorneys for Plaintiff 6 7 8 Dated: January 30, 2017 By: /s/ Marvin Pederson Marvin Pederson Attorney for Defendant Apena Corp. 9 10 11 MARVIN PEDERSON, ATTORNEY AT LAW Dated: January 30, 2017 12 VAN DE PEOL, LEVY, ALLEN & ARNEAL, LLP By: /s/ Nicolet E. Corliss Nicolet E. Corliss Attorneys for Defendants Demetrios Giannis and Rose Giannis 13 14 15 16 ORDER 17 22 23 of enforcing the parties’ Settlement Agreement and General Release should such enforcement be necessary. 26 27 D E ORDER Hon. IT IS SO Edward Chen ___ UNITED STATES DISTRICT COURT JUDGE hen rd M. C NO 28 2/2 Dated: _____________, 2017 UNIT ED 25 RT U O S 24 S DISTRICT TE C TA R NIA 21 IT IS FURTHER ORDERED that the Court shall retain jurisdiction for the purpose RT dwa Judge E FO 20 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 H ER LI 19 IT IS HEREBY ORDERED that this matter is dismissed with prejudice pursuant to A 18 N F D IS T IC T O R C

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