Opinion
DAVID P. FOOS, FOOS GAVIN LAW FIRM, P.C., Sacramento, CA, Attorney for Plaintiff, SAMBATH PROEUNG.
JEREMY A. MEIER, JENNIFER M. HOLLY, GREENBERG TRAURIG, LLP, Sacramento, CA, Attorneys for Defendant, MAXIMUS, Inc.
JOINT STIPULATION FOR DISMISSAL WITH PREJUDICE, PURSUANT TO F.R.C.P. RULE 41(a)(1); AND [PROPOSED] ORDER
KENDALL J. NEWMAN, Magistrate Judge.
WHEREAS Plaintiff SAMBATH PROEUNG and Defendant MAXIMUS, INC. agree that all claims in the above-captioned proceeding have been fully settled and compromised;
IT IS HEREBY STIPULATED by and between the parties to this action, through their undersigned counsel, that the above-captioned action be and hereby is dismissed with prejudice as to Defendant MAXIMUS, INC. pursuant to F.R.C.P. 41(a)(1);
IT IS FURTHER STIPULATED by and between the parties that each party shall bear its own attorneys' fee and costs of suit.
IT IS FURTHER STIPULATED by and between the parties that the parties mutually and fully release and forever discharge each other and their agents from any and all actions, suits, demands, debts, expenses, accounts, reckonings, obligations, costs, rights, agreements, promises, liabilities, liens, damages, or causes of action that may stem from any of the facts or causes of actions alleged in this lawsuit including, but not limited to, any and all claims known or unknown, including any common law claims, debts, liabilities, demands, damages, charges, promises, acts, agreements, claims for negligence, costs and expenses (including any claim for attorneys' fees), actions and causes of action, or any claim for violation of civil rights or of any other state or federal statute or constitution. This release extends to the parties SAMBATH PROEUNG and MAXIMUS, INC. in all capacities. [PROPOSED] ORDER
In view of the parties' Stipulation, the Court orders the above-captioned action be dismissed with prejudice, in its entirety. Each party to this action shall bear its own attorneys' fees and costs of suit.
IT IS SO ORDERED.