STIPULATION FOR DISMISSAL OF ACTION WITHOUT PREJUDICE

SUSAN ILLSTON, District Judge.

IT IS HEREBY STIPULATED by and between the parties, Plaintiffs PATRICIA JACKSON and MICHELLE JACKSON ("Plaintiffs"), and Defendants CLONEY'S PHARMACY, ANGELA MATTHEWS, and DOES 1 through 10 ("Defendants"), by and through their respective attorneys, as follows:

WHEREAS, Plaintiffs filed their Complaint on or about December 6, 2016;

WHEREAS, the parties have executed a Settlement and Release of Claims Agreement with an effective date of August 1, 2017;

WHEREAS, the Settlement and Release of Claims Agreement provides for Defendants to make monthly settlement payments to Plaintiffs on or before the 5th day of every month, for twenty four months (the "Term");

WHEREAS, the Settlement and Release of Claims Agreement provides for a dismissal of this entire action with prejudice on or before the last day of the last month of the Term; and

WHEREAS, the United States District Court, Northern District of California shall maintain jurisdiction over this matter until such time as a notice of dismissal with prejudice is filed, and in the event that Defendants stop making monthly payments before the end of the Term or before the settlement amount has been met, Plaintiffs may request this Court reopen the matter to enforce the terms of the Settlement and Release of Claims Agreement;

NOW, THEREFORE, IT IS HEREBY STIPULATED, pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure, by and between the Parties through their respective Counsel, that this matter be dismissed without prejudice effective immediately.

IT IS SO STIPULATED AND AGREED.