Ramirez v. Beijin Best, Inc. et al

Filing 24

STIPULATION AND ORDER DISMISSING ENTIRE ACTION WITH PREJUDICE. Signed by Judge Paul S. Grewal on September 12, 2011. (psglc1, COURT STAFF) (Filed on 9/12/2011)

1
2
3
4
5

CHRISTINE H. LONG, CA STATE BAR NO. 199676
KARA L. ARGUELLO, CA STATE BAR NO. 221093
BERLINER COHEN
TEN ALMADEN BOULEVARD
ELEVENTH FLOOR
SAN JOSE, CALIFORNIA 95113-2233
TELEPHONE: [phone]
FACSIMILE: [phone]
[e-mail]
[e-mail]

6
7
8

ATTORNEYS FOR DEFENDANTS BEIJING BEST, INC.;
MAXIM BEST CORPORATION; AND TAN YAN CHEUNG

12

JAMES DAL BON, CA STATE BAR NO. 157942
TOMAS E. MARGAIN, CA STATE BAR NO. 193555
DAL BON & MARGAIN, APC
28 NORTH 1ST STREET, SUITE 210
SAN JOSE, CA 95113
TEL [phone]
FAX [phone]
[e-mail]
[e-mail]

13

ATTORNEYS FOR PLAINTIFF JOSE RAMIREZ PAZ

9
10
11

14

UNITED STATES DISTRICT COURT

15

NORTHERN DISTRICT OF CALIFORNIA

16

SAN JOSE DIVISION

17

JOSE RAMIREZ PAZ,

18

Plaintiff,

19
20

CASE NO. CV 10-01720 PSG
NOTICE OF SETTLEMENT, AND
STIPULATION AND ORDER DISMISSING
ENTIRE ACTION WITH PREJUDICE

v.
BEIJIN BEST, INC.; MAXIM BEST
CORPORATION; TAN YAN CHEUNG,

21
Defendants.
22
23

NOTICE OF SETTLEMENT

24

Plaintiff Jose Ramirez Paz (“Plaintiff”) and Defendants Beijing Best, Inc., Maxim Best

25

Corporation and Tan Yan Cheung (collectively, “Defendants”), by and through their respective

26

attorneys of record, hereby notify the Court that the above-captioned matter was resolved

27

through informal settlement negotiations on or about May 31, 2011.

28

///
CASE NO. CV 10-01720 PSG

\KARGUELLO\855045.1
080211-14090010

-1-

NOTICE OF SETTLEMENT AND STIPULATION FOR ORDER DISMISSING ENTIRE ACTION WITH PREJUDICE

1
2
3
4
5

STIPULATION FOR ORDER DISMISSING ENTIRE ACTION WITH PREJUDICE
WHEREAS, the parties have fully executed a Confidential Settlement Agreement and
Release of Claims;
WHEREAS, Defendants have fully performed by paying the entire amount of settlement
as of June 27, 2011;

6

WHEREAS, no class was ever certified in this matter; therefore Rule 23 does not apply;

7

WHEREAS, all that remains to be done in this case is the entry of an Order dismissing

8
9
10

with prejudice the entire action;
THEREFORE, THE PARTIES HEREBY STIPULATE THAT:
1.

The Court should enter an Order dismissing with prejudice the entire action as to

11

all parties.

12

Dated: August 3, 2011

BERLINER COHEN

13
By /s/ Kara L. Arguello
KARA L. ARGUELLO
ATTORNEYS FOR DEFENDANTS
BEIJING BEST, INC., MAXIM BEST
CORPORATION AND TAN YAN
CHEUNG

14
15
16
17
18

Dated: August 3, 2011

DAL BON & MARGAIN

19

By /s/ James Dal Bon
JAMES DAL BON
ATTORNEYS FOR PLAINTIFF JOSE
RAMIREZ PAZ

20
21
22
23
24
25
26

ORDER
1.

The Court hereby issues an order dismissing with prejudice the entire action as to

all parties.
IT IS SO ORDERED.
Dated: _____________
September 12, 2011

27

_______________________________________
XXXXXXXXXXXXXX X
UNITED STATES DISTRICT COURT JUDGE
MAGISTRATE

28
CASE NO. CV 10-01720 PSG
\KARGUELLO\855045.1
080211-14090010

-2-

NOTICE OF SETTLEMENT AND STIPULATION FOR ORDER DISMISSING ENTIRE ACTION WITH PREJUDICE