Chapman v. O' Joes Inc. et al

Filing 25

STIPULATION AND ORDER OF DISMISSAL. Signed by Judge Richard Seeborg on 6/27/19. (cl, COURT STAFF) (Filed on 6/27/2019)

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THOMAS E. FRANKOVICH (State Bar #074414)
THOMAS E. FRANKOVICH,
A PROFESSIONAL LAW CORPORATION
1165 Hoff way, #203
Orland, CA 95963
Telephone: [phone]
Cell: 530-824-1000
Email: [e-mail]
Attorney for Plaintiff
BYRON CHAPMAN

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

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BYRON CHAPMAN,

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CASE NO. 3:18-CV-02451-RS

Plaintiff,

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STIPULATION OF DISMISSAL AND
[PROPOSED] ORDER THEREON

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v.

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Original Joe’s; O' Joes Inc., a California
Corp d.b.a. Original Joe’s; Sainte Claire
Building LLC, a California Limited Liability
Co.

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Defendants,

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The Parties, by and through their respective counsel, stipulate to dismissal of this action in

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its entirety with prejudice pursuant to Fed.R.Civ.P.41(a)(2).

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IT IS HEREBY STIPULATED by and between parties to this action through their

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designated counsel that the above-captioned action become and hereby is dismissed with prejudice

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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

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enforcement of the Agreement. See Kokonen v. Guardian Life Ins. Co., 511 U.S. 375 (1994)

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(empowering the district courts to retain jurisdiction over enforcement of settlement agreements).

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__________________________________________________________________________________________________________________
Stipulation of Dismissal and [proposed] Order Thereon
CASE NO. 5:18-CV-02451-NC

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IT IS SO STIPULATED.

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Respectfully Submitted,

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Dated: June18, 2019

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THOMAS E. FRANKOVICH, APLC
A PROFESSIONAL LAW CORPORATION

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By:

/s/ Thomas E. Frankovich

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Thomas E. Frankovich
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Attorneys for Plaintiff
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Dated: June 26, 2019

PATRICK STOKES

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By: /s/Patrick Stokes
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Patrick Stokes
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Attorneys for Defendant
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Dated: June 26, 2019

JOSPEH WALL

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By: /s/Jospeh Wall
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Joe Wall
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Attorney for St. Claire Building LLC
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__________________________________________________________________________________________________________________
Stipulation of Dismissal and [proposed] Order Thereon
CASE NO. 5:18-CV-02451-NC

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[proposed] ORDER

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

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

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ORDERED that the Court shall retain jurisdiction for the purpose of enforcing the parties’

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Settlement Agreement and General Release should such enforcement be necessary.

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Dated: _____________, 2017
June 27

______________________________

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Honorable Judge Richard Seeborg

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__________________________________________________________________________________________________________________
Stipulation of Dismissal and [proposed] Order Thereon
CASE NO. 5:18-CV-02451-NC

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