Filed: Jan. 05, 2016
Latest Update: Jan. 05, 2016
Summary: STIPULATION FOR ENTRY OF JUDGMENT AND [PROPOSED] ORDER EDWARD M. CHEN , District Judge . STIPULATION Plaintiffs Michael A. Russell Jr. and Jonathan Sassani ("Plaintiffs") and Defendants Synthes, Inc.; DePuy Synthes Sales, Inc.; Johnson & Johnson Services, Inc.; and Synthes USA Sales, LLC ("Defendants"), by and through their counsel of record, hereby jointly stipulate and agree as follows: WHEREAS, a full and final settlement of the above-entitled action has been entered and agreed to by a
Summary: STIPULATION FOR ENTRY OF JUDGMENT AND [PROPOSED] ORDER EDWARD M. CHEN , District Judge . STIPULATION Plaintiffs Michael A. Russell Jr. and Jonathan Sassani ("Plaintiffs") and Defendants Synthes, Inc.; DePuy Synthes Sales, Inc.; Johnson & Johnson Services, Inc.; and Synthes USA Sales, LLC ("Defendants"), by and through their counsel of record, hereby jointly stipulate and agree as follows: WHEREAS, a full and final settlement of the above-entitled action has been entered and agreed to by al..
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STIPULATION FOR ENTRY OF JUDGMENT AND [PROPOSED] ORDER
EDWARD M. CHEN, District Judge.
STIPULATION
Plaintiffs Michael A. Russell Jr. and Jonathan Sassani ("Plaintiffs") and Defendants Synthes, Inc.; DePuy Synthes Sales, Inc.; Johnson & Johnson Services, Inc.; and Synthes USA Sales, LLC ("Defendants"), by and through their counsel of record, hereby jointly stipulate and agree as follows:
WHEREAS, a full and final settlement of the above-entitled action has been entered and agreed to by all parties.
WHEREAS, Defendants presented both Plaintiffs with Offers of Judgment pursuant to Rule 68 of the Federal Rules of Civil Procedure, dated November 5, 2015. Plaintiffs each filed a separate "Notice of Acceptance" of Defendants' Rule 68 Offers of Judgment on November 23, 2015.
WHEREAS, the Parties have reached a mutual agreement regarding the payment of Plaintiffs' attorneys' fees and costs.
IT IS HEREBY STIPULATED AND AGREED THAT:
1. Judgment shall be entered in favor of Plaintiff Michael A. Russell, Jr. and against all Defendants pursuant to Defendants' Rule 68 Offer of Judgment accepted by Plaintiff Michael A. Russell, Jr. on November 23, 2015.
2. Judgment shall be entered in favor of Plaintiff Jonathan Sassani and against all Defendants pursuant to Defendants' Rule 68 Offer of Judgment accepted by Plaintiff Jonathan Sassani on November 23, 2015.
3. Defendants shall pay Plaintiffs' counsel reasonable attorneys' fees and costs in the amount mutually agreed upon by the Parties.
4. This judgment shall be binding upon the parties, their successors and assigns.
5. The Court shall retain jurisdiction of this case for purposes of enforcement of the Stipulated Judgment.
IT IS SO STIPULATED.
[PROPOSED] ORDER
This Court, having read the Stipulated Judgment of the Parties, and good cause appearing, hereby ORDERS THAT that the terms of the above stipulation are approved and adopted as the order of the Court as if set forth in full herein. The Clerk of the Court is directed to enter final judgment in this matter.
IT IS SO ORDERED.
