Opinion
CASE NO. CV-10-3145-LB
11-14-2011
IRMA RAMIREZ, an individual Plaintiffs, v. BILINGUAL BROADCASTING FOUNDATION, INC., a California Corporation dba KBBF 89.1 FM RADIO Defendants.
THOMAS E. FRANKOVICH A PROFESSIONAL LAW CORPORATION By: Thomas E. Frankovich Attorney for Plaintiff IRMA RAMIREZ LAW OFFICES OF NANCY A. PALANDATI By: Nancy A. Palandati Attorney for Defendant's BILINGUAL BROADCASTING FOUNDATION, INC., a California Corporation dba KBBF 89.1 FM RADIO
THOMAS E. FRANKOVICH (State Bar #074414)
THOMAS E. FRANKOVICH
A PROFESSIONAL LAW CORPORATION
Attorneys for Plaintiff IRMA RAMIREZ
STIPULATION OF DISMISSAL AND [PROPOSED] ORDER THEREON
The parties, by and through their respective 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).
Therefore, IT IS HEREBY STIPULATED by and between parties to this action through their designated counsel that the above-captioned action be and hereby is dismissed with prejudice 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.
THOMAS E. FRANKOVICH
A PROFESSIONAL LAW CORPORATION
By: Thomas E. Frankovich
Attorney for Plaintiff IRMA RAMIREZ
LAW OFFICES OF NANCY A. PALANDATI
By: Nancy A. Palandati
Attorney for Defendant's BILINGUAL
BROADCASTING FOUNDATION, INC., a
California Corporation dba KBBF 89.1 FM RADIO
ORDER
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 purpose of enforcing the parties' Settlement Agreement and General Release should such enforcement be necessary
Honorable Judge Laurel Beeler
UNITED STATE DISTRICT JUDGE
Therefore, IT IS HEREBY STIPULATED by and between parties to this action through their designated counsel that the above-captioned action be and hereby is dismissed with prejudice 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.
THOMAS E. FRANKOVICH
A PROFESSIONAL LAW CORPORATION
By: Thomas E. Frankovich
Attorney for Plaintiff IRMA RAMIREZ
LAW OFFICES OF NANCY A. PALANDATI
By: Nancy A. Palandati
Attorney for Defendant's BILINGUAL
BROADCASTING FOUNDATION, INC., a
California Corporation dba KBBF 89.1 FM RADIO
ORDER
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 purpose of enforcing the parties' Settlement Agreement and General Release should such enforcement be necessary The November 17, 2011 status conference is VACATED.
Honorable Judge Laurel Beeler
UNITED STATE DISTRICT JUDGE