UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
June 22, 2011
MARSHALL LOSKOT, AN INDIVIDUAL,
EL CHARRO RESTAURANT;
WELLINGTON UGARTE PALACIOS; BLANCA UGARTE PALACIOS; AND UGARTE-PALACIOS, INC., A CALIFORNIA CORPORATION,
The opinion of the court was delivered by: Honorable Magistrate Judge Laurel Beeler United States District Judge
STIPULATION OF DISMISSAL AND [PROPOSED] ORDER THEREON
The parties, by and through their respective counsel, stipulate to dismissal of this action in 19 its entirety with prejudice pursuant to Fed.R.Civ.P.41(a)(1). Outside of the terms of the Settlement Agreement and General Release ("Agreement") herein, each party is to bear its own costs and attorneys' fees. The parties further consent to and request that the Court retain 22 jurisdiction over enforcement of the Agreement. See Kokonen v. Guardian Life Ins. Co., 511 U.S. 375 (1994) (empowering the district courts to retain jurisdiction over enforcement of settlement agreements).
Therefore, IT IS HEREBY STIPULATED by and between parties to this action through 2 their designated counsel that the above-captioned action be and hereby is dismissed with prejudice 3 pursuant to Federal Rules of Civil Procedure section 41(a)(1).
This stipulation may be executed in counterparts, all of which together shall constitute one original document.
Dated: June 13, 2011
THOMAS E. FRANKOVICH A PROFESSIONAL LAW CORPORATION By: Thomas E. Frankovich Attorneys for Plaintiff MARSHALL LOSKOT Dated: June , 2011 JEFFER, MANGELS, BUTLER & 13 MITCHELL, LLP By: Martin H. Orlick Attorney for Defendants, WELLINGTON UGARTE; and UGARTE-PALACIOS, INC.,
IT IS HEREBY ORDERED that this matter is dismissed with prejudice pursuant to Fed.R.Civ.P.41(a)(1). IT IS FURTHER ORDERED that the Court shall retain jurisdiction for the 22 purpose of enforcing the parties' Settlement Agreement and General Release should such 23 enforcement be necessary.
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