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Samuel Castillo v. Trinity Protection Services

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


December 13, 2010

SAMUEL CASTILLO,
PLAINTIFF,
v.
TRINITY PROTECTION SERVICES, INC. AND DOES 1 THROUGH 50, INCLUSIVE,
DEFENDANTS.

The opinion of the court was delivered by: Hon. Susan Illston

CLIFFORD E. YIN (State Bar No. 173159) NA'IL BENJAMIN (State Bar No. 240354) COBLENTZ, PATCH, DUFFY & BASS LLP One Ferry Building, Suite 200 San Francisco, California 94111-4213 Telephone: 415.391.4800 Facsimile: 415.989.1663 Email: ef-cey@cpdb.com, ef-nxb@cpdb.com Attorneys for Defendant Trinity Protection Services, Inc.

STIPULATED DISMISSAL WITH PREJUDICE AND WITHOUT COSTS AND [PROPOSED] ORDER

IT IS HEREBY stipulated and agreed by and between the parties in the above captioned action that pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii), all allegations, claims and 20 prayers for relief in this litigation brought by Plaintiff, Samuel Castillo ("Mr. Castillo), against Trinity Protection Services, Inc. ("Trinity"), are hereby dismissed with prejudice and without costs 22 or attorneys' fees ("Dismissal") according to the following terms hereby made fully a part of the Court's Order:

Mr. Castillo covenants, on behalf of himself and his heirs, successors and assigns, that neither he nor they will file, participate in, or instigate the filing of any lawsuits, complaints, or charges in any state or federal court or any proceedings before any local, administrative, state, or federal agency, or in any other forum, except under legal compulsion, claiming that any of the Released Parties have violated any law or obligation based upon events or omissions occurring prior to the Court's Order dismissing this matter with prejudice, including, but not limited to, any claims that have been or could have been asserted in this action and any claims that could have been asserted in any other action. Mr. Castillo understands, acknowledges, and agrees that all such claims, liabilities or causes of action, including, without limitation, any claim for attorneys' fees and costs, are forever barred by this Dismissal, regardless of the forum in which they may be brought.

This existence of, and circumstances related to, this Dismissal are strictly confidential, except to the extent disclosure thereof is required by law. Unless compelled by law, Mr. Castillo agrees not to disclose, either directly or indirectly, the existence of, and/or circumstances related to, this Dismissal to any third party, other than his attorney, spouse, accountant, or tax preparer, provided that he first informs each of these persons of the nature and extent of this confidentiality obligation and secures his or her agreement not to disclose the existence of, and circumstances related to, this Dismissal to any third party. Without limiting the foregoing, Mr. Castillo agrees that he shall not discuss the Action or the existence of, and circumstances related to, this Dismissal with any current or former employee of Trinity, and shall not suggest to any person, either directly or indirectly, that he received valuable consideration as a result of making a demand on or filing the Action or that any such person would receive valuable consideration as a result of taking legal action against Trinity or any of the other Related Parties. Mr. Castillo agrees that a violation of this provision, in any way, is a breach of the Court's Order.

STIPULATED AND AGREED

ORDER

Pursuant to the Stipulation set forth above, IT IS HEREBY ORDERED that:

1. This action is dismissed with prejudice and without costs;

2. The dismissal is expressly conditioned on the following:

Mr. Castillo covenants, on behalf of himself and his heirs, successors and assigns, that neither he nor they will file, participate in, or instigate the filing of any lawsuits, complaints, or charges in any state or federal court or any proceedings before any local, administrative, state, or federal agency, or in any other forum, except under legal compulsion, claiming that any of the Released Parties have violated any law or obligation based upon events or omissions occurring prior to the Court's Order dismissing this matter with prejudice, including, but not limited to, any claims that have been or could have been asserted in this action and any claims that could have been asserted in any other action. Mr. Castillo understands, acknowledges, and agrees that all such claims, liabilities or causes of action, including, without limitation, any claim for attorneys' fees and costs, are forever barred by this Dismissal, regardless of the forum in which they may be brought.

This existence of, and circumstances related to, this Dismissal are strictly confidential, except to the extent disclosure thereof is required by law. Unless compelled by law, Mr. Castillo agrees not to disclose, either directly or indirectly, the existence of, and/or circumstances related to, this Dismissal to any third party, other than his attorney, spouse, accountant, or tax preparer, provided that he first informs each of these persons of the nature and extent of this confidentiality obligation and secures his or her agreement not to disclose the existence of, and circumstances related to, this Dismissal to any third party. Without limiting the foregoing, Mr. Castillo agrees that he shall not discuss the Action or the existence of, and circumstances related to, this Dismissal with any current or former employee of Trinity, and shall not suggest to any person, either directly or indirectly, that he received valuable consideration as a result of making a demand on or filing the Action or that any such person would receive valuable consideration as a result of taking legal action against Trinity or any of the other Related Parties. Mr. Castillo agrees that a violation of this provision, in any way, is a breach of the Court's Order.

3. This Court shall retain jurisdiction over this matter for purposes of enforcing the terms and conditions set forth herein.

The Clerk shall close this file.

Dated: _________________, 2010 _________________________________

Honorable Susan Illston United States District Judge

20101213

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