Filed: Aug. 01, 2017
Latest Update: Aug. 01, 2017
Summary: STIPULATION FOR CONTINGENT DISMISSAL; [PROPOSED] ORDER EDWARD J. DAVILA , District Judge . STIPULATION FOR CONTINGENT DISMISSAL The parties stipulate as follow: 1. In this ERISA collection action, the parties have reached an agreement to settle this case pursuant to the terms and conditions specified in a Settlement Agreement. 2. The Settlement Agreement requires Defendants to make timely monthly payments to Plaintiffs, with the final payment to be received by May 31, 2018. 3. If t
Summary: STIPULATION FOR CONTINGENT DISMISSAL; [PROPOSED] ORDER EDWARD J. DAVILA , District Judge . STIPULATION FOR CONTINGENT DISMISSAL The parties stipulate as follow: 1. In this ERISA collection action, the parties have reached an agreement to settle this case pursuant to the terms and conditions specified in a Settlement Agreement. 2. The Settlement Agreement requires Defendants to make timely monthly payments to Plaintiffs, with the final payment to be received by May 31, 2018. 3. If th..
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STIPULATION FOR CONTINGENT DISMISSAL; [PROPOSED] ORDER
EDWARD J. DAVILA, District Judge.
STIPULATION FOR CONTINGENT DISMISSAL
The parties stipulate as follow:
1. In this ERISA collection action, the parties have reached an agreement to settle this case pursuant to the terms and conditions specified in a Settlement Agreement.
2. The Settlement Agreement requires Defendants to make timely monthly payments to Plaintiffs, with the final payment to be received by May 31, 2018.
3. If the Settlement Agreement is breached, the parties agree that Plaintiffs may reopen this case and file the Stipulated Judgment attached hereto as "Exhibit 1."
The parties therefore respectfully request that the Court contingently dismiss this case pursuant to the above terms.
IT IS SO STIPULATED AND AGREED.
IT IS SO ORDERED.
Exhibit 1
Benjamin K. Lunch (SB #246015)
Wan Yan Ling (SB # 297029)
NEYHART, ANDERSON, FLYNN & GROSBOLL
369 Pine Street, Suite 800
San Francisco, CA 94104-3323
Tel. (415) 677-9440
Fax (415) 677-9445
Email: blunch@neyhartlaw.com
wling@neyhartlaw.com
Attorneys for Plaintiffs
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
(San Jose Division)
SACRAMENTO AREA ELECTRICAL Case No. 17-CV-1074-EJD
WORKERS HEALTH & WELFARE
TRUST; SACRAMENTO AREA STIPULATED JUDGMENT
ELECTRICAL WORKERS PENSION
TRUST; SACRAMENTO AREA
ELECTRICAL WORKERS JOINT
APPRENTICESHIP & TRAINING TRUST;
SACRAMENTO AREA ELECTRICAL
WORKERS LABOR MANAGEMENT
COOPERATION COMMITTEE FUND;
SACRAMENTO AREA ELECTRICAL
WORKERS CONTRACT
ADMINISTRATION FUND; BOB WARD,
as trustee of the above trusts except for the
SACRAMENTO AREA ELECTRICAL
WORKERS PENSION TRUST; JEFF
STORY, as trustee of the SACRAMENTO
AREA ELECTRICAL WORKERS
PENSION TRUST; NATIONAL
ELECTRICAL BENEFIT FUND; and
INTERNATIONAL BROTHERHOOD OF
ELECTRICAL WORKERS LOCAL UNION
NO. 340
Plaintiffs,
v.
CROSS ELECTRIC and DENNIS DAMIEN
CROSS,
Defendants.
The parties stipulate that judgment shall be entered in favor of Plaintiffs and against Defendants, jointly and severally, in the amount of $26,811.77, less all amounts received by Plaintiffs on the Settlement Agreement dated June 12, 2017, and plus all amounts currently owed by Defendants to Plaintiffs on said Settlement Agreement, Collective Bargaining Agreement,1 and applicable Trust Agreement(s), to wit: _______________.
IT IS SO STIPULATED AND AGREED.
Dated: June 12, 2017 By: _______________________________
WAN YAN LING
Attorney for Plaintiffs
Neyhart, Anderson, Flynn & Grosboll
Dated: 6/14/2017 By: _______________________________
CROSS ELECTRIC
Dated: 6/14/2017 By: _______________________________
DENNIS DAMIEN CROSS
IT IS SO ORDERED.
