Filed: Oct. 26, 2019
Latest Update: Oct. 26, 2019
Summary: STIPULATION FOR WAIVER OF FEES AND COSTS IN EXCHANGE FOR WAIVER OF RIGHT TO APPEAL AND [PROPOSED] ORDER THEREON JENNIFER L. THURSTON , Magistrate Judge . Plaintiff TATYANA HARGROVE ("Plaintiff") and Defendants CITY OF BAKERSFIELD, BAKERSFIELD POLICE DEPARTMENT OFFICER CHRISTOPHER MOORE, and BAKERSFIELD POLICE DEPARTMENT SENIOR OFFICER GEORGE VASQUEZ ("Defendants"), by and through their counsel of record, hereby stipulate to the terms and conditions on this stipulation and jointly requ
Summary: STIPULATION FOR WAIVER OF FEES AND COSTS IN EXCHANGE FOR WAIVER OF RIGHT TO APPEAL AND [PROPOSED] ORDER THEREON JENNIFER L. THURSTON , Magistrate Judge . Plaintiff TATYANA HARGROVE ("Plaintiff") and Defendants CITY OF BAKERSFIELD, BAKERSFIELD POLICE DEPARTMENT OFFICER CHRISTOPHER MOORE, and BAKERSFIELD POLICE DEPARTMENT SENIOR OFFICER GEORGE VASQUEZ ("Defendants"), by and through their counsel of record, hereby stipulate to the terms and conditions on this stipulation and jointly reque..
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STIPULATION FOR WAIVER OF FEES AND COSTS IN EXCHANGE FOR WAIVER OF RIGHT TO APPEAL AND [PROPOSED] ORDER THEREON
JENNIFER L. THURSTON, Magistrate Judge.
Plaintiff TATYANA HARGROVE ("Plaintiff") and Defendants CITY OF BAKERSFIELD, BAKERSFIELD POLICE DEPARTMENT OFFICER CHRISTOPHER MOORE, and BAKERSFIELD POLICE DEPARTMENT SENIOR OFFICER GEORGE VASQUEZ ("Defendants"), by and through their counsel of record, hereby stipulate to the terms and conditions on this stipulation and jointly request that the court enter its Order at the end of this document.
RECITALS
WHEREAS, the Court entered Judgment in favor of Defendants and against Plaintiff on October 21, 2019.
WHEREAS, Defendants are entitled to their costs incurred in defense of this action and have agreed to waive those costs in exchange for Plaintiff's waiver of her right to appeal the Judgment of this case.
WHEREAS, Plaintiff has a right to appeal the Court's Judgment and has agreed to waive her right to appeal in exchange for a waiver of costs and fees by the Defendants.
STIPULATION
Therefore, the Parties agree as follows:
Plaintiff agrees to waive her right to all appealable issues arising in and from this action, including but not limited to the October 21, 2019 Judgment in exchange for Defendants' waiver of all claims for costs and fees arising from this litigation.
Dated: October 26, 2019 ALDERLAW, P.C.
/s/ Neil K. Gehlawat
By:________________________________
Neil K. Gehlawat
Attorneys for Plaintiff
TATYANA HARGROVE
Dated: October 26, 2019 THE LAW OFFICE OF THOMAS C. SEABAUGH
/s/ Thomas C. Seabaugh
By:________________________________
Thomas C. Seabaugh
Attorneys for Plaintiff
TATYANA HARGROVE
Dated: October 26, 2019 MARDEROSIAN & COHEN
/s/ Michael G. Marderosian
By:________________________________
Michael G. Marderosian,
Attorneys for Defendants
above-named.
ORDER
Upon good cause being shown as set forth in the Stipulation of legal counsel for the Parties, the Court hereby adopts the Stipulation.
IT IS SO ORDERED.