Chapman v. Baechtel Creek Inn Inc et al

Filing 11

STIPULATION AND ORDER OF DISMISSAL. Signed by Judge Richard Seeborg on 1/8/18. (cl, COURT STAFF) (Filed on 1/8/2018)

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THOMAS E. FRANKOVICH (State Bar #074414)
AMANDA LOCKHART (State Bar #289900)
THOMAS E. FRANKOVICH,
A PROFESSIONAL LAW CORPORATION
702 Mangrove Avenue, #304
Chico, CA 95926
Telephone: [phone]
Email: [e-mail]
Attorney for Plaintiff
BYRON CHAPMAN

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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BYRON CHAPMAN,

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Plaintiff,

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v.
BAECHTEL CREEK INN, INC., et al.

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Defendants.

) CASE NO. 3:17-cv-05727-RS
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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).

Stipulation

Case No. 17-05727

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Dated: January 5, 2018

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THOMAS E. FRANKOVICH, APLC
A PROFESSIONAL LAW CORPORATION
By: /s/ Amanda Lockhart
Amanda Lockhart
Attorneys for Plaintiff

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Dated: January 5, 2018

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NEARY and O’BRIEN
By: /s/ Christopher J. Neary
Christopher J. Neary
Attorney for Defendants

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[proposed] 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

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

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

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necessary.

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Dated: _________________________
1/8/18

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_______________________________
Honorable Richard Seeborg
United States District Judge

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Stipulation

Case No. 17-05727