Ramirez v. Bilingual Broadcasting Foundation Inc

Filing 29

STIPULATION AND ORDER re 28 . The November 17, 2011 status conference is VACATED. Signed by Judge Laurel Beeler on 11/14/2011. (lblc2, COURT STAFF) (Filed on 11/14/2011)

Case4:10-cv-03145-LB Document28

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THOMAS E. FRANKOVICH (State Bar #074414)
THOMAS E. FRANKOVICH
A PROFESSIONAL LAW CORPORATION
4328 Redwood Hwy, Suite 300
San Rafael, CA 94903
Telephone:
415/674-8600
Facsimile:
415/674-9900

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Filed11/14/11 Page1 of 3

Attorneys for Plaintiff IRMA RAMIREZ

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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IRMA RAMIREZ, an individual
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Plaintiffs,
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v.
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BILINGUAL BROADCASTING
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FOUNDATION, INC., a California
Corporation dba KBBF 89.1 FM RADIO )
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,
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Defendants.
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___________________________________ )

CASE NO. CV-10-3145-LB
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

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in its entirety with prejudice pursuant to Fed.R.Civ.P.41(a)(1). Outside of the terms of the

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Settlement Agreement and General Release (“Agreement”) herein, each party is to bear its own

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costs and attorneys’ fees. The parties further consent to and request that the Court retain

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jurisdiction over enforcement of the Agreement. See Kokonen v. Guardian Life Ins. Co., 511

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U.S. 375 (1994) (empowering the district courts to retain jurisdiction over enforcement of

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settlement agreements).

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STIPULATION OF DISMISSAL AND [PROPOSED] ORDER THEREON

CASE NO.CV-10-3145-LB

Case4:10-cv-03145-LB Document28

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

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their designated counsel that the above-captioned action be and hereby is dismissed with

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prejudice pursuant to Federal Rules of Civil Procedure section 41(a)(1).

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This stipulation may be executed in counterparts, all of which together shall constitute
one original document.

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Dated: November 14, 2011

THOMAS E. FRANKOVICH
A PROFESSIONAL LAW CORPORATION

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By: /s/ Thomas E. Frankovich
Thomas E. Frankovich
Attorney for Plaintiff IRMA RAMIREZ

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Dated: ______________, 2011

LAW OFFICES OF NANCY A. PALANDATI

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By: __________________________
Nancy A. Palandati

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Attorney for Defendant’s BILINGUAL
BROADCASTING FOUNDATION, INC., a
California Corporation dba KBBF 89.1 FM RADIO

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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)(1). IT IS FURTHER ORDERED that the Court shall retain jurisdiction for

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the purpose of enforcing the parties’ Settlement Agreement and General Release should such

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enforcement be necessary

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Dated: _____________, 2011

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Honorable Judge Laurel Beeler
UNITED STATE DISTRICT JUDGE

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STIPULATION OF DISMISSAL AND [PROPOSED] ORDER THEREON

CASE NO.CV-10-3145-LB

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Case4:10-cv-03145-LB Document28

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The November 17, 2011 status conference is VACATED.
November 14