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 DEFENDANT AMERICAN MULTI- CINEMA, INC. (ERRONEOUSLY SUED HEREIN AS AMERICAN MULTI- CINEMA, INC. dba AMC THEATERS); [PROPOSED] ORDER
IT IS HEREBY STIPULATED by and between Plaintiffs Alma Clarisa Hernandez, Theresa Wallen and Ronald Moore ("Plaintiffs") and Defendant American Multi-Cinema, Inc. 20 (erroneously sued herein as American Multi-Cinema, Inc. dba AMC Theaters) ("Defendant") 21 that pursuant to Federal Rule of Civil Procedure 41(a)(2), Defendant American Multi-Cinema, 22 Inc. (erroneously sued herein as American Multi-Cinema, Inc. dba AMC Theaters) be dismissed 23 with prejudice from this action. 24
IT IS FURTHER STIPULATED between Plaintiffs and Defendant that this case has 25 been settled as between them and all issues and controversies have been resolved to their 26 mutual satisfaction. Plaintiffs and Defendant American Multi-Cinema, Inc. request the Court to 27 retain jurisdiction to enforce the terms of their settlement agreement under the authority of 28 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: comply with the terms of the confidential Settlement Agreement and Release in Full, the terms 18 of which are incorporated herein by reference.
2. By consent of Plaintiff Ronald Moore and Defendant American Multi-Cinema, 1. Plaintiff Ronald Moore and Defendant American Multi-Cinema, Inc. shall 20 Inc., the Court shall retain jurisdiction in this matter for the purpose of enforcing the terms of 21 the settlement agreement. 22 3. Except as provided for in paragraphs 1 and 2 above, Defendant American Multi- Cinema, Inc. is dismissed with prejudice from this action.
United States District Court Judge
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