Navarro -v- Arrow Electronics

Filing 44

Order Granting 43 Stipulation of Dismissal with Prejudice. The Clerk shall close this file. Signed by Hon. Edward J. Davila on 9/14/2012.(ecg, COURT STAFF) (Filed on 9/14/2012)

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Thomas M. McInerney, SBN 162055
[e-mail]
Erica K. Rocush, SBN 262354
[e-mail],
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
Steuart Tower, Suite 1300
One Market Plaza
San Francisco, CA 94105
Telephone:
415.442.4810
Facsimile:
415.442.4870

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Attorneys for Defendant
ARROW ELECTRONICS, INC.

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GERALD EMANUEL, State Bar No. 61049
[e-mail]
HINKLE, JACHIMOWICZ, POINTER & EMANUEL
2007 West Hedding Street, Suite 100
San Jose, California 95128
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff
KATHY NAVARRO

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IN THE UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA
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KATHY NAVARRO, an individual,
Plaintiff,

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Case No. CV 10 3210 EJD

v.
ARROW ELECTRONICS, INC., a New York
corporation; and DOES 1-50, inclusive,

STIPULATION AND [PROPOSED]
ORDER FOR DISMISSAL OF
COMPLAINT WITH PREJUDICE
PURSUANT TO FRCP 41

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Defendants.
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WHEREAS, Plaintiff Kathy Navarro (“Plaintiff” or “Navarro”) and Defendant Arrow
Electronics, Inc. (“Defendant” or “Arrow”) (collectively, “the Parties”) have agreed to fully settle
Case No. CV 10 3210 EJD

STIPULATION AND [PROPOSED] ORDER OF DISMISSAL
Request for
dismissal

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the instant action;
WHEREAS, the Parties have entered into a settlement and executed a Confidential

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Settlement Agreement resolving all of Plaintiff’s claims against Defendant, including all claims

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arising under the Federal Age Discrimination in Employment Act (“ADEA,” 29 U.S.C. § 621, et.

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seq.) in exchange for valuable consideration;

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NOW THEREFORE, the Parties hereby jointly and respectfully request that the Court,

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pursuant to Federal Rule of Civil Procedure 41(a)(1), discontinue and dismiss with prejudice the

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above-titled action as to all parties, with each party bearing her or its own fees and costs.

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DATED: September __, 2012

OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

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By: /s/ Erica K. Rocush __________________
Thomas M. McInerney
Erica K. Rocush
Attorneys for Defendant Arrow
Electronics, Inc.

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DATED: September ___, 2012

HINKLE, JACHIMOWICZ, POINTER &
EMANUEL

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By: /s/ Gerald Emanuel
Gerald Emanuel
Attorneys for Plaintiff Kathy Navarro

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Case No. CV 10 3210 EJD

STIPULATION AND [PROPOSED] ORDER OF DISMISSAL
Request for
dismissal

XxxxxxxxxX
[PROPOSED] ORDER

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Having been advised by the Parties that a Settlement Agreement was entered into,

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pursuant to which Plaintiff Kathy Navarro has agreed to release all claims, including all claims

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arising under the Federal Age Discrimination in Employment Act (“ADEA,” 29 U.S.C. § 621, et.

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seq.) against defendant Arrow Electronics, Inc. in exchange for valuable consideration, the matter

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of Kathy Navarro v. Arrow Electronics, Inc., et al., United States District Court, Northern District

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of California, Case No. C 10-3210 EJD, is, by reason of the settlement, hereby dismissed with

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prejudice in its entirety as to all parties, each party to bear her or its own costs and fees.

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IT IS SO ORDERED. The Clerk shall close this file.
September 14, 2012
Dated:_____________________

______________________________
Hon. Edward J. Davila
United States District Court

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Case No. CV 10 3210 EJD

STIPULATION AND [PROPOSED] ORDER OF DISMISSAL
Request for
dismissal