NOTICE OF SETTLEMENT, AND STIPULATION AND ORDER DISMISSING ENTIRE ACTION WITH PREJUDICE
Plaintiff Jose Ramirez Paz ("Plaintiff") and Defendants Beijing Best, Inc., Maxim Best Corporation and Tan Yan Cheung (collectively, "Defendants"), by and through their respective 26 attorneys of record, hereby notify the Court that the above-captioned matter was resolved 27 through informal settlement negotiations on or about May 31, 2011.
WHEREAS, the parties have fully executed a Confidential Settlement Agreement and Release of Claims;
WHEREAS, Defendants have fully performed by paying the entire amount of settlement as of June 27, 2011;
WHEREAS, no class was ever certified in this matter; therefore Rule 23 does not apply;
WHEREAS, all that remains to be done in this case is the entry of an Order dismissing 8 with prejudice the entire action;
THEREFORE, THE PARTIES HEREBY STIPULATE THAT:
1. The Court should enter an Order dismissing with prejudice the entire action as to all parties.
Dated: August 3, 2011 BERLINER COHEN 13 By /s/ Kara L. Arguello 14 KARA L. ARGUELLO 15 ATTORNEYS FOR DEFENDANTS BEIJING BEST, INC., MAXIM BEST 16 CORPORATION AND TAN YAN CHEUNG 17 Dated: August 3, 2011 DAL BON & MARGAIN 18 19 By /s/ James Dal Bon 20 JAMES DAL BON ATTORNEYS FOR PLAINTIFF JOSE 21 RAMIREZ PAZ
1. The Court hereby issues an order dismissing with prejudice the entire action as to all parties.
UNITED STATES DISTRICT COURT JUDGE ...