STIPULATION FOR DISMISSAL OF ACTION AND COURT RETENTION OF JURISDICTION TO ADJUDICATE PLAINTIFF'S CLAIM FOR HER ATTORNEYS' FEES, COSTS, AND LITIGATION EXPENSES; [PROPOSED] ORDER

SUSAN ILLSTON, Senior District Judge.

IT IS HEREBY STIPULATED by and between Plaintiff, Francisca Moralez ("Plaintiff"), and Defendants, Home Depot U.S.A., Inc. dba The Home Depot; and HD Development of Maryland, Inc. (collectively "Defendants," and together with Plaintiff, the "Parties"), the parties hereto, through their respective attorneys of record, that pursuant to Federal Rule of Civil Procedure 41(a)(2), the above-captioned action be dismissed with prejudice.

IT IS FURTHER STIPULATED between the Parties that the Court shall expressly retain jurisdiction over this matter for the purpose of adjudicating any subsequent motion Plaintiff may bring to recover her reasonable attorneys' fees, costs, and litigation expenses. Any such motion shall be filed within 60 days of the date the Court issues its Order on this stipulation.

IT IS FURTHER STIPULATED between the Parties that Defendants, solely for purposes of the Fees Claim, will not oppose Plaintiff's attorneys' fees motion on the grounds that Plaintiff purports to be the prevailing party in this Action.

IT IS SO STIPULATED.

ATTESTATION

Concurrence in the filing of this document has been obtained from each of the individual(s) whose electronic signature is attributed above.

ORDER

The Parties having so stipulated and good cause appearing,

IT IS HEREBY ORDERED as follows:

1. The Court shall expressly retain jurisdiction over this matter for the purpose of adjudicating any motion brought by Plaintiff to recover her attorneys' fees, costs, and litigation expenses ("Fees Claim").

2. Plaintiff shall file any Fees Claim within 60 days of the date of this Order.

3. Except as provided for in paragraph 1, the action is dismissed with prejudice and all dates and events are hereby VACATED.

IT IS SO ORDERED.