STIPULATION FOR DEFENDANT LOS RIOS COMMUNITY COLLEGE DISTRICT'S NON-OPPOSITION AND RELEASE FROM COSTS AND FEES; ORDER

KIMBERLY J. MUELLER, District Judge.

RECITALS

WHEREAS, on March 28, 2019, Plaintiffs Kristine Kurk and Susan Shroll ("Plaintiffs") filed a lawsuit against the defendants listed in the caption above, including the Los Rios Community College District and the President of its Board of Trustees, John Knight (referenced together below as the "LRCCD Defendants");

WHEREAS, on or about March 29, 2019, Plaintiffs' counsel mailed the LRCCD Defendants a "Notice of a Lawsuit and Request to Waive Service of a Summons";

WHEREAS, on April 26, 2019, counsel for the LRCCD Defendants mailed Plaintiffs' counsel executed waivers of service for the LRCCD Defendants;

WHEREAS, at all relevant times in this lawsuit, Plaintiff Kurk was a Los Rios Community College District employee;

WHEREAS, all allegations against the LRCCD Defendants in the complaint filed by Plaintiffs on March 28, 2019 ("Complaint") result from events and circumstances arising from Plaintiff Kurk's employment with the Los Rios Community College District and her participation in the Los Rios Classified Employees Association;

WHEREAS, if Plaintiffs prevail in this lawsuit, they will be entitled to recover their attorneys' fees and costs from the defendants;

WHEREAS, the LRCCD Defendants are not interested in contesting the merits of the allegations in the Complaint or being exposed to payment of Plaintiffs' costs and attorneys' fees should Plaintiffs ultimately prevail;

THEREFORE, Plaintiffs and the LRCCD Defendants (collectively referenced as "the Parties") hereby stipulate as follows:

STIPULATION

IT IS HEREBY STIPULATED by and between the Parties, by and through their respective counsel of record, that the LRCCD Defendants shall remain as defendants in Plaintiffs' lawsuit, but shall not oppose or otherwise contest the allegations or underlying legal theories in the Complaint. In exchange for the LRCCD Defendants' agreement not to oppose the allegations or underlying legal theories in the Complaint, Plaintiffs shall waive their right to recover attorneys' fees and costs from the LRCCD Defendants if Plaintiffs prevail in the lawsuit.

This Stipulation does not prevent or limit Plaintiffs' ability to conduct discovery or the LRCCD Defendants' ability to object to and oppose Plaintiffs' discovery requests.

Should the LRCCD Defendants oppose the allegations or underlying legal theories in the Complaint, this Stipulation shall be null and void.

SO STIPULATED.

IT IS SO ORDERED.