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Contract analysis / stipulation-of-dismissal.docx
stipulation-of-dismissal.docx
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1. Dismissal of All Claims With Prejudice. All claims, causes of action, and demands of a
Standard
⚑ Commercial term
1. Dismissal of All Claims With Prejudice. All claims, causes of action, and demands of any kind asserted by Plaintiffs against Defendant in this Action, including all claims set forth in Plaintiffs' Complaint filed on April 17, 2023, are hereby dismissed with prejudice. All counterclaims and affirmative defenses asserted by Defendant against Plaintiffs in this Action are likewise hereby dismissed with prejudice. Eac
2. Retention of Jurisdiction. The Parties respectfully request that the Court retain juri
2. Retention of Jurisdiction. The Parties respectfully request that the Court retain jurisdiction over this Action solely for the limited purpose of enforcing the terms and conditions of the Settlement Agreement. In accordance with Kokkonen v. Ridgeline Mutual Insurance, 511 U.S. 375, 381–82 (1994), the Parties expressly request that the Court incorporate the Settlement Agreement's terms by reference into this Stipul
3. Consent of All Parties. This Stipulation is filed with the written consent of all Part
Standard
⚑ Commercial term
3. Consent of All Parties. This Stipulation is filed with the written consent of all Parties who have appeared in this Action. No other party has appeared or been served in this Action, and accordingly no additional consent is required under Federal Rule of Civil Procedure 41(a)(1)(A)(ii). DATED: August 14, 2023 CALDERWOOD & HARKNESS LLP By: ________ Alan Ngo (SBN 198742) 777 South Figueroa Street, 34th Floor Los Ang