Yang et al v. Colliss et al

Filing 66

JOINT STIPULATION AND ORDER FOR DISMISSAL. Signed by Judge Richard Seeborg on 3/15/19. (cl, COURT STAFF) (Filed on 3/15/2019)

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Leslie R. Perry, Bar No. 062390
Michael G. Miller, Bar No. 136491
Nicole M. Jaffee, Bar No. 255944
PERRY, JOHNSON, ANDERSON,
MILLER & MOSKOWITZ, LLP
438 1st Street, 4th Floor
Santa Rosa, California 95401
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Defendants/CrossClaimants/Cross- Defendants
MAUREEN B. COLLISS, an individual,
MAUREEN B. COLLISS, TRUSTEE OF
THE MAUREEN B. COLLISS 2000
TRUST, JOSEPH COLLISS aka JOE
COLLISS, an individual

UNITED STATES DISTRICT COURT

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MILLER & MOSKOWITZ LLP

PERRY, JOHNSON, ANDERSON,

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NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO

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CHIN S. YANG, an individual, and LIHUA C. YANG, an individual,

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Plaintiffs,

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Case No. 3:17-cv-6658-RS

JOINT STIPULATION FOR
DISMISSAL AND [PROPOSED]
ORDER

v.
MAUREEN B. COLLISS, an individual,
MAUREEN B. COLLISS, TRUSTEE OF
THE MAUREEN B. COLLISS 2000
TRUST, JOSEPH COLLISS aka JOE
COLLISS, an individual, and SONOMA
COUNTY AGRICULTURAL
PRESERVATION AND OPEN SPACE
DISTRICT, a California public agency,
Defendants.
/
AND RELATED CROSS-CLAIMS
/

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WHEREAS, plaintiffs Chin S. Yang and Li-Hua C. Yang (hereinafter “the Yang

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Parties”) filed their First Amended Complaint against defendants Maureen B. Colliss, Maureen

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B. Colliss, Trustee of the Maureen B. Colliss 2000 Trust, Joseph Colliss aka Joe Colliss
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JOINT STIPULATION FOR DISMISSAL AND [PROPOSED] ORDER

Case No. 3:17-cv-6658-RS

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(hereinafter “the Colliss Parties”) and Sonoma County Agricultural Preservation and Open

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Space District, a California public agency (hereinafter “the District”) on November 21, 2017;

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the Colliss Parties filed counterclaims against the Yang Parties and crossclaims against the

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District on January 9, 2018; the District filed counterclaims against the Colliss Parties and

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crossclaims against the Yang Parties on January 30, 2018 and the Yang Parties filed

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counterclaims against the Colliss Parties on February 1, 2018 and counterclaims against the

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District on February 12, 2018;

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WHEREAS, the Yang Parties, the Colliss Parties and the District settled this matter on
or about February 26, 2019;
THEREFORE, IT IS HEREBY STIPULATED by and between the Yang Parties, the
Colliss Parties and the District through their designated counsel that the above-captioned

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MILLER & MOSKOWITZ LLP

PERRY, JOHNSON, ANDERSON,

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action should be dismissed with prejudice pursuant to Federal Rule of Civil Procedure

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41(a)(1)(A)(i). The parties further stipulate that, except as set forth in the Settlement

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Agreement between them, the parties shall bear their own attorney’s fees, expenses and costs.

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By signing this Joint Stipulation for Dismissal and [Proposed] Order, the counsel for

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each party listed below concurs in its filing. This document is being filed through the

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Electronic Case Filing system by attorney Nicole M. Jaffee. By her signature, she attests that

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the Colliss Parties have obtained concurrence in the filing of this document from each counsel

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signing the stipulation, pursuant to Civil Local Rule 5-1.

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IT IS SO STIPULATED.
DATED: March 14, 2019

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MERLIN LAW GROUP

BRUCE D. GOLDSTEIN, COUNTY
COUNSEL

/s/ Victor Jacobellis
VICTOR JACOBELLIS
Attorneys for Plaintiffs/CrossClaimants/Cross-Defendants
CHIN S. YANG, an individual, and LIHUA C. YANG, an individual

/s/ Michael A. King
MICHAEL A. KING
Deputy County Counsel
Attorneys for Defendant/CrossClaimant/Cross-Defendant
SONOMA COUNTY AGRICULTURAL
PRESERVATION AND OPEN SPACE
DISTRICT
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JOINT STIPULATION FOR DISMISSAL AND [PROPOSED] ORDER

Case No. 3:17-cv-6658-RS

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PERRY, JOHNSON, ANDERSON,
MILLER & MOSKOWITZ, LLP

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/s/ Nicole M. Jaffee
LESLIE R. PERRY
MICHAEL G. MILLER
NICOLE M. JAFFEE
Attorneys for Defendants/CrossClaimants/Cross-Defendants
MAUREEN B. COLLISS, an individual,
MAUREEN B. COLLISS, TRUSTEE OF
THE MAUREEN B. COLLISS 2000
TRUST, JOSEPH COLLISS aka JOE
COLLISS, an individual

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MILLER & MOSKOWITZ LLP

PERRY, JOHNSON, ANDERSON,

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JOINT STIPULATION FOR DISMISSAL AND [PROPOSED] ORDER

Case No. 3:17-cv-6658-RS

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ORDER
The Court having considered the stipulation of the parties, orders as follows:

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The action is dismissed with prejudice as against Defendants/Cross-

Defendants/Counter-Defendants MAUREEN B. COLLISS, an individual, MAUREEN
B. COLLISS, TRUSTEE OF THE MAUREEN B. COLLISS 2000 TRUST, JOSEPH
COLLISS aka JOE COLLISS, an individual; and Defendant/Cross-Defendant/Counter-

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Defendant SONOMA COUNTY AGRICULTURAL PRESERVATION AND OPEN

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SPACE DISTRICT; and Cross-Defendants/Counter-Defendants CHIN S. YANG, an

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individual, and LI-HUA C. YANG, an individual, pursuant to Federal Rule of Civil

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Procedure 41(a)(1)(A)(i).
2.

Each party shall bear their own attorney’s fees, costs and expenses.

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3.

The Court shall retain jurisdiction over this matter to enforce the terms of the

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MILLER & MOSKOWITZ LLP

PERRY, JOHNSON, ANDERSON,

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February 26, 2019 Settlement Agreement.

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IT IS SO ORDERED.

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DATED: March ____, 2019

___________________________________________
UNITED STATES DISTRICT COURT JUDGE
RICHARD SEEBORG

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JOINT STIPULATION FOR DISMISSAL AND [PROPOSED] ORDER

Case No. 3:17-cv-6658-RS