STIPULATION FOR DISMISSAL OF ACTION WITH PREJUDICE AND [] ORDER FOR COURT TO RETAIN JURISDICTION TO ENFORCE SETTLEMENT AGREEMENT

RONALD M. WHYTE, District Judge.

IT IS HEREBY STIPULATED by and between Plaintiff ABIGAYIL TAMARA on the one hand and Defendant EL CAMINO HOSPITAL on the other hand, the parties to this action, by and through their respective counsel, that pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii), the above-captioned action be dismissed with prejudice in its entirety. Each side shall pay its own attorneys' fees and costs except as expressly set forth in the Court-Enforceable Settlement Agreement And Release ("Settlement Agreement and Release"). Defendant agrees to the dismissal with prejudice.

Further, Plaintiff and Defendant have entered into the attached Settlement Agreement and Release which settles all aspects of the lawsuit against Defendant without admission by any party of wrongdoing, liability, or fault. The Settlement Agreement and Release states in part-that "The Court shall retain jurisdiction to enforce this Agreement pursuant to the Dismissal of Action with Prejudice and a [Proposed] Order for which is attached hereto as Exhibit A." To ensure that the parties have the ability to seek this Court's help in enforcing enforcement of the Settlement Agreement and Release, the parties respectfully ask the Court to retain jurisdiction to enforce the terms of the Settlement Agreement and Release if it is necessary. Plaintiff and Defendant Stipulate to the Court retaining jurisdiction to enforce the Settlement Agreement and Release and its Exhibit A.

This Stipulation and Order may be signed in counterparts, and facsimile or electronically transmitted signatures shall be valid and binding as original signatures.

Wherefore, Plaintiff and Defendant, by and through their attorneys of record, so stipulate.

[] ORDER

Pursuant to the Settlement Agreement and Release, and for good cause shown, the Court shall retain jurisdiction of this action to enforce provisions of this Settlement Agreement and General Release for thirty-six (36) months after the date of entry of this Order by the Court, or until injunctive relief is complete, whichever occurs later.