Opinion
Case No. C05-0454 JL.
October 5, 2005
THOMAS E. FRANKOVICH (State Bar No. 074414), JULIA M. ADAMS (State Bar No. 230795), THOMAS E. FRANKOVICH, A Professional Law Corporation, San Francisco, CA, Attorneys for Plaintiffs, MARSHALL LOSKOT and DISABILITY RIGHTS ENFORCEMENT, EDUCATION SERVICES: HELPING YOU HELP OTHERS.
KRISTEN M. PEZONE, LEWIS, BRISBOIS, BISGAARD SMITH LLP, Attorneys for Defendants, JAMES J. BERNARD and RAYNA G. BERNARD; and JAMES J. BERNARD INC., a California corporation dba LA BARCA.
STIPULATION OF DISMISSAL AND [ PROPOSED] ORDER THEREON
Plaintiffs MARSHALL LOSKOT and DISABILITY RIGHTS ENFORCEMENT, EDUCATION SERVICES, by and through their counsel, and defendants LA BARCA; JAMES J. BERNARD and RAYNA G. BERNARD; and JAMES J. BERNARD INC., a California corporation, by and through their counsel, stipulate to dismissal of this action in 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 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).
This stipulation may be executed in counterparts, all of which together shall constitute one original document.
ORDER
IT IS SO ORDERED.