Rodriguez v. County of Santa Clara et al

Filing 14

STIPULATION AND ORDER GRANTING REQUEST FOR PERMITTING PLAINTIFF ALBERT LARA RODRIGUEZ TO DISMISS WITH PREJUDICE ALL CLAIMS AGAINST ALL DEFENDANTS re 13 Stipulation. The Clerk shall close this file. Signed by Judge Edward J. Davila on 1/26/2012. (ecg, COURT STAFF) (Filed on 1/26/2012)

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1 Wesley Wakeford (SBN 224801)
The Wakeford Law Firm
2 550 California Street
3 Sacramento Tower, Suite 700
San Francisco, California 94104
4 Telephone: [phone]
Facsimile: [phone]
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Attorney for Plaintiff
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ALBERT LARA RODRIGUEZ
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UNITED STATES DISTRICT COURT

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1/26/2012

NORTHERN DISTRICT OF CALIFORNIA

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Case No. 5:11-CV-02622-EJD

ALBERT LARA RODRIGUEZ
Plaintiff,
vs.

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COUNTY OF SANTA CLARA; SANTA
CLARA COUNTY DEPARTMENT OF
CORRECTION; EDWARD C. FLORES,
individually and in his capacity as former
Director of the Santa Clara County Department
of Corrections; and DOES 1 through 100,
inclusive

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STIPULATION PERMITTING
PLAINTIFF ALBERT LARA
RODRIGUEZ TO DISMISS WITH
PREJUDICE ALL CLAIMS AGAINST
ALL DEFENDANTS

Defendants.

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Pursuant to Federal Rule of Civ. Proc. 41(a)(1) and Local Rule 77-2(c), Plaintiff Albert
Lara Rodriguez and Defendants County of Santa Clara; Santa Clara County Department of
Correction; and Edward C. Flores, each stipulate to permit Plaintiff Albert Lara Rodriguez to
dismiss with prejudice all claims asserted in this action against each and every Defendant. It is

25 further stipulated that Defendants County of Santa Clara; Santa Clara County Department of
26 Correction; and Edward C. Flores each waive all rights to any claim they may have against
27 Plaintiff Albert Lara Rodriguez for the recovery of attorneys fees or costs.
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STIPULATED DISMISSAL
CV11-02622 EJD

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The undersigned attorneys of record for the various parties to this action each certify that
they are fully authorized by the party or parties represented to agree to and enter into this
stipulation permitting Plaintiff Albert Lara Rodriguez to dismiss with prejudice all claims
asserted against Defendants County of Santa Clara; Santa Clara County Department of

5 Correction; and Edward C. Flores. The terms of this Stipulation shall become effective upon the
6 Court’s approval and entry of this Stipulation.
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Accordingly, the parties each respectfully request that the Court approve and enter

8 Plaintiff Albert Lara Rodriguez’s dismissal with prejudice of all claims asserted against
9 Defendants County of Santa Clara; Santa Clara County Department of Correction; and Edward C.
10 Flores. Additionally, the parties further stipulate and request that the Court retain jurisdiction to
11 oversee compliance with this Stipulation and to resolve any issues, disputes, or questions
12 regarding Plaintiff’s dismissal of Defendants. (See Kokkonen v. Guardian Life Ins. Co. of
13 America, 511 U.S. 375 (1994).
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16 Dated: January 24, 2012
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By:___ /S/_________________
Wesley Wakeford
Attorney for Plaintiff
Albert Lara Rodriguez

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By:___/S/___________________
John L. Winchester, III
Attorney for Defendants
County of Santa Clara, Santa
Clara County Department of
Correction; and Edward C. Flores

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STIPULATED DISMISSAL
CV11-02622 EJD

IT IS SO ORDERED. The Clerk shall close this file.
Dated: January 26, 2012
___________________________
Edward J. Davila
United States District Judge