JOINT STIPULATONA ND ORDER OF DISMISSAL OF ENTIRE ACTION, WITH PREJUDICE AS TO PLAINTIFFS, AND WITHOUT PREJUDICE AS TO THE PUTATIVE CLASS

LAWRENCE K. KARLTON, District Judge.

TO THE HONORABLE COURT AND TO ALL PARTIES AND COUNSEL:

WHEREFORE, Plaintiffs ELIZABETH CHARLES, KAYLA HOPKINS, DREW QUEEN, JULIO VELASQUEZ, BRONSON MARTINEZ, EDWINA FELISE, ALEC PICKLE, JAMIE WILLIAMS, STEVI LUKE, AARON MORY, and MELISSA SELL (collectively "Plaintiffs") and Defendants BELL BROTHERS HEATING AND AIR, INC., KENNY BELL and JERRY BELL, (collectively "Defendants"), by and through their respective attorneys of record, hereby stipulate to dismissal of the entire action as to all parties and all causes of action, with prejudice as to Plaintiffs, and without prejudice as to the putative class, and without any award for attorneys' fees or costs to any Party; each Party to bear her/his/its own attorneys' fees and costs.

WHEREFORE, this case was brought as a putative class action under Rule 23 of the Federal Rules of Civil Procedure ("FRCP"), and as a putative representative action under California Labor Code section 2698, et seq. [the Private Attorneys General Act ("PAGA")]. The putative class has not been certified. The Parties exchanged extensive information and data to assess the claims and to explore potential early resolution. After so doing, the Parties explored potential settlement of Plaintiffs' individual claims. After extensive arms-length negotiations, the Parties reached confidential individual settlements with Plaintiffs in exchange for general releases and dismissal with prejudice of their individual claims. Plaintiffs elected not to pursue the putative class and collective action claims. No consideration was provided for the dismissal without prejudice of the putative class and representative claims, and dismissal without prejudice as to the putative class will not affect the potential class members.

WHEREFORE, the Parties hereby stipulate and agree to dismissal of the entire action as to all parties and all causes of action, with prejudice as to Plaintiffs, and without prejudice as to the putative class, and without any award for attorneys' fees or costs to any Party; each Party to bear her/his/its own attorneys' fees and costs.

IT IS SO STIPULATED AND AGREED.

ORDER

IT IS HEREBY ORDERED the entire action is dismissed as to all Parties and all causes of action, with prejudice as to Plaintiffs, and without prejudice as to the putative class, and without any award for attorneys' fees or costs to any Party; each Party to bear her/his/its own attorneys' fees and costs.

IT IS SO ORDERED.