Filed: Mar. 10, 2020
Latest Update: Mar. 10, 2020
Summary: STIPULATION FOR DEFENDANT LOS RIOS COMMUNITY COLLEGE DISTRICT'S NON-OPPOSITION AND RELEASE FROM COSTS AND FEES; ORDER JOHN A. MENDEZ , District Judge . RECITALS WHEREAS, on February 28, 2020, Plaintiff Dawn Woltkam filed a lawsuit against the Defendants listed in the caption above, including Los Rios Community College District and the former President of its Board of Trustees, John Knight (referenced together below as the "LRCCD Defendants"); and WHEREAS, on March 6, 2020, the LRCCD Defe
Summary: STIPULATION FOR DEFENDANT LOS RIOS COMMUNITY COLLEGE DISTRICT'S NON-OPPOSITION AND RELEASE FROM COSTS AND FEES; ORDER JOHN A. MENDEZ , District Judge . RECITALS WHEREAS, on February 28, 2020, Plaintiff Dawn Woltkam filed a lawsuit against the Defendants listed in the caption above, including Los Rios Community College District and the former President of its Board of Trustees, John Knight (referenced together below as the "LRCCD Defendants"); and WHEREAS, on March 6, 2020, the LRCCD Defen..
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STIPULATION FOR DEFENDANT LOS RIOS COMMUNITY COLLEGE DISTRICT'S NON-OPPOSITION AND RELEASE FROM COSTS AND FEES; ORDER
JOHN A. MENDEZ, District Judge.
RECITALS
WHEREAS, on February 28, 2020, Plaintiff Dawn Woltkam filed a lawsuit against the Defendants listed in the caption above, including Los Rios Community College District and the former President of its Board of Trustees, John Knight (referenced together below as the "LRCCD Defendants"); and
WHEREAS, on March 6, 2020, the LRCCD Defendants were served with the Summons and Complaint; and
WHEREAS, at all relevant times in this lawsuit, Plaintiff was a Los Rio Community College District employee; and
WHEREAS, all allegations against the LRCCD Defendants in the complaint filed by Plaintiff on February 28, 2020 ("Complaint"), result from events and circumstances arising from Plaintiff's employment with the Los Rios Community College District, and her participation in the Los Rios Classified Employees Association; and
WHEREAS, the LRCCD Defendants are not interested in contesting the merits of the allegations in the Complaint or being exposed to payment of Plaintiff's costs and attorneys' fees should Plaintiff ultimately prevail.
NOW THEREFORE, Plaintiff and the LRCCD Defendants (collectively referred to herein as "the Parties") hereby stipulate as follows:
STIPULATION
IT IS HEREBY STIPULATED by and between the Parties, by and through their respective counsel of record, that the LRCCD Defendants shall remain as defendants in Plaintiff's lawsuit, but shall not oppose or otherwise contest the allegations or underlying legal theories in the Complaint. In exchange for the LRCCD Defendants' agreement not to oppose the allegations or underlying legal theories in the Complaint, Plaintiff shall waive her right to recover attorneys' fees and costs from the LRCCD Defendants if Plaintiff prevails in the lawsuit.
Should the LRCCD Defendants oppose the allegations or underlying legal theories in the Complaint this Stipulation will be null and void.
SO STIPULATED.
Dated: March 9, 2020 PARKER & COVERT LLP
By: /s/ Spencer E. Covert
Spencer E. Covert
Attorneys for Defendants Los Rios
Community College District, and John Knight
Dated: March 9, 2020 FREEDOM FOUNDATION
By: /s/ Karen Sweigart as authorized on 3/9/20
Karen Sweigart
Shella Sadovnik
Attorneys for Plaintiff Dawn Woltkamp
IT IS SO ORDERED.
