Trostenetsky v. The Keys Condominium Owners Association

Filing 66

STIPULATION AND ORDER DISMISSING ACTION WITH PREJUDICE AND RETAINING JURISDICTION OVER THE SETTLEMENT AGREEMENT. Signed by Judge Richard Seeborg on 1/23/19. (cl, COURT STAFF) (Filed on 1/23/2019)

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ALLACCESS LAW GROUP
Irene Karbelashvili, State Bar Number 232223
[e-mail]
Irakli Karbelashvili, State Bar Number 302971
[e-mail]
19 North Second Street, Suite 205
San Jose, CA 95113
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for BRONYA TROSTENETSKY, Plaintiff

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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Case No. 3:17-cv-04167-RS

BRONYA TROSTENETSKY,
Plaintiff,
vs.

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THE KEYS CONDOMINIUM OWNERS
ASSOCIATION, a business entity form
unknown; and DOES 1-10, Inclusive,

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STIPULATION AND [PROPOSED]
ORDER DISMISSING ACTION WITH
PREJUDICE AND RETAINING
JURISDICTION OVER THE
SETTLEMENT AGREEMENT

Defendants

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IT IS HEREBY STIPULATED by and between Plaintiff BRONYA TROSTENETSKY
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(“Plaintiff”) and Defendant THE KEYS CONDOMINIUM OWERS ASSOCIATION

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(“Defendant”)(collectively, the “Parties”), through undersigned their undersigned counsel, that

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that this action be dismissed with prejudice in its entirety. Each side is to bear her/its own

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attorneys' fees, costs, and litigation expenses. The Parties FURTHER STIPULATE and request

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Case No. 3:17-CV-04167-RS
Stipulation and [Proposed] Order

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that the Court retain jurisdiction over enforcement of the terms of the settlement agreement
which terms are conditioned upon future remediation.
Respectfully submitted,

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Dated: January 21, 2019

ALLACCESS LAW GROUP
By: /s/ Irakli Karbelashvili
IRAKLI KARBELASHVILI, Attorney for
Plaintiff BRONYA TROSTENETSKY

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Dated: January 22, 2019

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HARTSUYKER, STRATMAN & WILLIAMSABREGO
By: /s/ Robert M. Maltz
ROBERT M. MALTZ, Attorney for DEFENDANT
THE KEYS CONDOMINIUM OWNERS
ASSOCIATION

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FILER’S ATTESTATION
Pursuant to Local Rule 5-1, I hereby attest that on January 22, 2019, I, received the
concurrence of Robert M. Maltz, Esq. in the filing of this document

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By:/s/ Irakli Karbelashvili
IRAKLI KARBELASHVILI

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Page 2 of 3
Case No. 3:17-CV-04167-RS
Stipulation and [Proposed] Order

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[PROPOSED] ORDED

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Having reviewed the above stipulation, and for good cause shown, this action is

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dismissed with prejudice with each side bearing her/its own attorneys’ fees, costs, and litigation

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expenses. The Court retains jurisdiction over the parties’ settlement agreement.

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Dated: __________
1/23/19

_______________________
United States District Judge

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Page 3 of 3
Case No. 3:17-CV-04167-RS
Stipulation and [Proposed] Order