K. Randolph Moore, SBN 106933 Tanya E. Moore, SBN 206683 MOORE LAW FIRM, P.C. 332 North Second Street San Jose, California 95112 Telephone: (408) 298-2000 Facsimile: (408) 298-6046 Attorneys for Plaintiffs Alma Clarisa Hernandez, Theresa Wallen 1nd Ronald Moore
STIPULATION FOR DISMISSAL OF HASHIM BANGLESH AND MABEL GUNSKI dba SPORTS ACTION ONLY; [PROPOSED] ORDER
IT IS HEREBY STIPULATED by and between Plaintiffs Alma Clarisa Hernandez, Theresa Wallen and Ronald Moore ("Plaintiffs") through their attorney of record, and Defendant Hashim Banglesh ("Defendant") who is self-represented, that pursuant to Federal Rule of Civil Procedure 41(a)(2), Defendant Hashim Banglesh dba Sports Action be dismissed with prejudice from this action.
IT IS FURTHER STIPULATED between Plaintiffs and Defendant that this case has been settled as between them and all issues and controversies have been resolved to their mutual satisfaction. Plaintiff Ronald Moore and Defendant request the Court to retain jurisdiction to enforce the terms of their settlement agreement under the authority of Kokkonen v. Guardian Life Ins. Co. of America, 511 U.S. 375, 381-82 (1994).
The parties having so stipulated,
IT IS HEREBY ORDERED as follows:
1. Plaintiff Ronald Moore and Defendant Hashim Banglesh dba Sports Action shall comply with the terms of the confidential Settlement Agreement and Release in Full, the terms of which are incorporated herein by reference.
2. By consent of Plaintiff Ronald Moore and Defendant Hashim Banglesh dba Sports Action, the Court shall retain jurisdiction in this matter for the purpose of enforcing the 18 terms of the settlement agreement.
3. Except as provided for in paragraphs 1 and 2 above, Defendant Hashim Banglesh is dismissed with prejudice from this action.
United States District Court Judge
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