Filed: Mar. 12, 2018
Latest Update: Mar. 12, 2018
Summary: STIPULATION FOR DISMISSAL OF ACTION; [PROPOSED] ORDER (AS MODIFIED) SUSAN VAN KEULEN , Magistrate Judge . IT IS HEREBY STIPULATED by and between Plaintiff Francisca M. Moralez ("Plaintiff") and Defendants Bong Hae Lee dba Cork-N-Bottle; Chin Ki Lee dba Cork-N-Bottle; Patricia S. Work, as Trustee of the Bypass Trust established under the Work Family 2002 Revocable Trust u/d/t dated August 29, 2002, and as Trustee of the Work Marital Trust under the Work Family 2002 Revocable Trust u/d
Summary: STIPULATION FOR DISMISSAL OF ACTION; [PROPOSED] ORDER (AS MODIFIED) SUSAN VAN KEULEN , Magistrate Judge . IT IS HEREBY STIPULATED by and between Plaintiff Francisca M. Moralez ("Plaintiff") and Defendants Bong Hae Lee dba Cork-N-Bottle; Chin Ki Lee dba Cork-N-Bottle; Patricia S. Work, as Trustee of the Bypass Trust established under the Work Family 2002 Revocable Trust u/d/t dated August 29, 2002, and as Trustee of the Work Marital Trust under the Work Family 2002 Revocable Trust u/d/..
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STIPULATION FOR DISMISSAL OF ACTION; [PROPOSED] ORDER (AS MODIFIED)
SUSAN VAN KEULEN, Magistrate Judge.
IT IS HEREBY STIPULATED by and between Plaintiff Francisca M. Moralez ("Plaintiff") and Defendants Bong Hae Lee dba Cork-N-Bottle; Chin Ki Lee dba Cork-N-Bottle; Patricia S. Work, as Trustee of the Bypass Trust established under the Work Family 2002 Revocable Trust u/d/t dated August 29, 2002, and as Trustee of the Work Marital Trust under the Work Family 2002 Revocable Trust u/d/t dated August 29, 2002; Alison Work Sola; and Susan Work Ward (collectively "Defendants"), by and through their respective counsel, that pursuant to Federal Rule of Civil Procedure 41(a)(2), this action be dismissed with prejudice.
IT IS FURTHER STIPULATED between Plaintiff and Defendants that this case has been settled as between them and all issues and controversies have been resolved to their mutual satisfaction. Plaintiff and Defendants request that the Court retain jurisdiction to enforce the terms of their settlement agreement under the authority of Kokkonen v. Guardian Life Ins. Co. of America, 511 U.S. 375, 381-82 (1994).
ATTESTATION
Concurrence in the filing of this document has been obtained from each of the individual(s) whose electronic signature is attributed above.
/s/ Tanya E. Moore
Tanya E. Moore
Attorneys forP laintiff
Francisca M. Moralez
ORDER
The parties having so stipulated,
IT IS HEREBY ORDERED as follows:
1. Plaintiff Francisca M. Moralez ("Plaintiff"), and Defendants Bong Hae Lee dba Cork-N-Bottle; Chin Ki Lee dba Cork-N-Bottle; Patricia S. Work, as Trustee of the Bypass Trust established under the Work Family 2002 Revocable Trust u/d/t dated August 29, 2002, and as Trustee of the Work Marital Trust under the Work Family 2002 Revocable Trust u/d/t dated August 29, 2002; Alison Work Sola; and Susan Work Ward (collectively "Defendants") shall comply with the terms of the confidential Settlement Agreement and Limited Release, the terms of which are incorporated herein by reference.
2. By consent of Plaintiff and Defendants, the Court shall retain jurisdiction in this matter for the purpose of enforcing the terms of the settlement agreement.
3. Except as provided for in paragraphs 1 and 2 above, this action is dismissed with prejudice.
IT IS SO ORDERED.