stipulation-for-dismissal.docx

1035-00004 · Client 1035 · Pleadings

stipulation-for-dismissal.docx DOCUMENT Litigation

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Samuel Eklund (SBN 198456) Jeffrey Park (SBN 302814) CALDERWOOD & HARKNESS LLP 725 South Flower Street, Suite 4200 Los Angeles, California 90017 Telephone: (213) 555-8200 Facsimile: (213) 555-8201

Attorneys for Plaintiff MARGUERITE D. FONSECA

Elaine Chow (SBN 247190) Marcus Webb (SBN 318042) HARGROVE, PETTIT & SUN LLP 800 South Figueroa Street, Suite 3100 Los Angeles, California 90017 Telephone: (213) 555-6100

Attorneys for Defendants DESMOND R. RENNICK and RENNICK SLATE VENTURES LLC

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:

The parties to this action, Plaintiff Marguerite D. Fonseca ("Plaintiff"), on the one hand, and Defendants Desmond R. Rennick and Rennick Slate Ventures LLC (collectively, "Defendants"), on the other hand, by and through their respective counsel of record, hereby stipulate and agree as follows:

1. Plaintiff's Complaint, filed on January 24, 2023, and all causes of action alleged therein, including but not limited to the First Cause of Action for Breach of Fiduciary Duty, the Second Cause of Action for Breach of Partnership Agreement, the Third Cause of Action for Accounting, the Fourth Cause of Action for Constructive Fraud, and the Fifth Cause of Action for Unjust Enrichment, is hereby dismissed in its entirety, with prejudice, as to all Defendants named therein, including DOES 1 through 25, inclusive.

2. Defendants' Counterclaim, filed on March 6, 2023, and all causes of action alleged therein, is hereby dismissed in its entirety, with prejudice, as to Plaintiff and all other parties against whom such Counterclaim was asserted.

3. Each party shall bear its own attorney's fees and costs incurred in connection with this action. No party shall be deemed the prevailing party for any purpose, including for purposes of any contractual or statutory provision authorizing the recovery of attorney's fees and costs.

4. Pursuant to California Code of Civil Procedure Section 664.6, the Court shall retain jurisdiction over the parties to enforce the terms of the Settlement Agreement and Mutual Release dated July 14, 2023, entered into by and among Marguerite D. Fonseca, Desmond R. Rennick, and Rennick Slate Ventures LLC. The parties request that the Court incorporate the terms of said Settlement Agreement and Mutual Release by reference for purposes of enforcement under Section 664.6, to the extent necessary to resolve any disputes arising thereunder.

[SIGNATURES ON FOLLOWING PAGE]

DATED: August _, 2023

CALDERWOOD & HARKNESS LLP

By: ________

Samuel Eklund Attorneys for Plaintiff MARGUERITE D. FONSECA

DATED: August _, 2023

HARGROVE, PETTIT & SUN LLP

By: ________

Elaine Chow Attorneys for Defendants DESMOND R. RENNICK and RENNICK SLATE VENTURES LLC

ORDER

Good cause appearing from the foregoing Joint Stipulation of the parties, and the Court having reviewed and considered the Stipulation and all papers filed in connection therewith,

IT IS HEREBY ORDERED as follows:

1. The Complaint filed by Plaintiff Marguerite D. Fonseca on January 24, 2023, and all causes of action alleged therein, including the First Cause of Action for Breach of Fiduciary Duty, the Second Cause of Action for Breach of Partnership Agreement, the Third Cause of Action for Accounting, the Fourth Cause of Action for Constructive Fraud, and the Fifth Cause of Action for Unjust Enrichment, is hereby dismissed with prejudice as to all Defendants, including DOES 1 through 25, inclusive.

2. The Counterclaim filed by Defendants Desmond R. Rennick and Rennick Slate Ventures LLC on March 6, 2023, and all causes of action alleged therein, is hereby dismissed with prejudice as to Plaintiff and all other parties against whom such Counterclaim was asserted.

3. Each party shall bear its own attorney's fees and costs incurred in connection with this action.

4. This Court retains jurisdiction pursuant to California Code of Civil Procedure Section 664.6 to enforce the terms of the Settlement Agreement and Mutual Release dated July 14, 2023, entered into by and among Marguerite D. Fonseca, Desmond R. Rennick, and Rennick Slate Ventures LLC.

IT IS SO ORDERED.

DATED: _____

________________________________________

Judge of the Superior Court

MARGUERITE D. FONSECA, an individual,	Case No. 23STCV01897
Plaintiff,	JOINT STIPULATION FOR DISMISSAL OF ENTIRE ACTION WITH PREJUDICE

vs.

DESMOND R. RENNICK, an individual; RENNICK SLATE VENTURES LLC, a California limited liability company; and DOES 1 through 25, inclusive,

Defendants.

Samuel Eklund (SBN 198456) Jeffrey Park (SBN 302814) CALDERWOOD & HARKNESS LLP 725 South Flower Street, Suite 4200 Los Angeles, California 90017 Telephone: (213) 555-8200 Facsimile: (213) 555-8201
Attorneys for Plaintiff MARGUERITE D. FONSECA
Elaine Chow (SBN 247190) Marcus Webb (SBN 318042) HARGROVE, PETTIT & SUN LLP 800 South Figueroa Street, Suite 3100 Los Angeles, California 90017 Telephone: (213) 555-6100
Attorneys for Defendants DESMOND R. RENNICK and RENNICK SLATE VENTURES LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:
The parties to this action, Plaintiff Marguerite D. Fonseca ("Plaintiff"), on the one hand, and Defendants Desmond R. Rennick and Rennick Slate Ventures LLC (collectively, "Defendants"), on the other hand, by and through their respective counsel of record, hereby stipulate and agree as follows:
1. Plaintiff's Complaint, filed on January 24, 2023, and all causes of action alleged therein, including but not limited to the First Cause of Action for Breach of Fiduciary Duty, the Second Cause of Action for Breach of Partnership Agreement, the Third Cause of Action for Accounting, the Fourth Cause of Action for Constructive Fraud, and the Fifth Cause of Action for Unjust Enrichment, is hereby dismissed in its entirety, with prejudice, as to all Defendants named therein, including DOES 1 through 25, inclusive.
2. Defendants' Counterclaim, filed on March 6, 2023, and all causes of action alleged therein, is hereby dismissed in its entirety, with prejudice, as to Plaintiff and all other parties against whom such Counterclaim was asserted.
3. Each party shall bear its own attorney's fees and costs incurred in connection with this action. No party shall be deemed the prevailing party for any purpose, including for purposes of any contractual or statutory provision authorizing the recovery of attorney's fees and costs.
4. Pursuant to California Code of Civil Procedure Section 664.6, the Court shall retain jurisdiction over the parties to enforce the terms of the Settlement Agreement and Mutual Release dated July 14, 2023, entered into by and among Marguerite D. Fonseca, Desmond R. Rennick, and Rennick Slate Ventures LLC. The parties request that the Court incorporate the terms of said Settlement Agreement and Mutual Release by reference for purposes of enforcement under Section 664.6, to the extent necessary to resolve any disputes arising thereunder.
[SIGNATURES ON FOLLOWING PAGE]
DATED: August _, 2023
CALDERWOOD & HARKNESS LLP
By: ________
Samuel Eklund Attorneys for Plaintiff MARGUERITE D. FONSECA
DATED: August _, 2023
HARGROVE, PETTIT & SUN LLP
By: ________
Elaine Chow Attorneys for Defendants DESMOND R. RENNICK and RENNICK SLATE VENTURES LLC
ORDER
Good cause appearing from the foregoing Joint Stipulation of the parties, and the Court having reviewed and considered the Stipulation and all papers filed in connection therewith,
IT IS HEREBY ORDERED as follows:
1. The Complaint filed by Plaintiff Marguerite D. Fonseca on January 24, 2023, and all causes of action alleged therein, including the First Cause of Action for Breach of Fiduciary Duty, the Second Cause of Action for Breach of Partnership Agreement, the Third Cause of Action for Accounting, the Fourth Cause of Action for Constructive Fraud, and the Fifth Cause of Action for Unjust Enrichment, is hereby dismissed with prejudice as to all Defendants, including DOES 1 through 25, inclusive.
2. The Counterclaim filed by Defendants Desmond R. Rennick and Rennick Slate Ventures LLC on March 6, 2023, and all causes of action alleged therein, is hereby dismissed with prejudice as to Plaintiff and all other parties against whom such Counterclaim was asserted.
3. Each party shall bear its own attorney's fees and costs incurred in connection with this action.
4. This Court retains jurisdiction pursuant to California Code of Civil Procedure Section 664.6 to enforce the terms of the Settlement Agreement and Mutual Release dated July 14, 2023, entered into by and among Marguerite D. Fonseca, Desmond R. Rennick, and Rennick Slate Ventures LLC.
IT IS SO ORDERED.
DATED: _____
________________________________________
Judge of the Superior Court
MARGUERITE D. FONSECA, an individual, | Case No. 23STCV01897
Plaintiff, | JOINT STIPULATION FOR DISMISSAL OF ENTIRE ACTION WITH PREJUDICE
vs.
DESMOND R. RENNICK, an individual; RENNICK SLATE VENTURES LLC, a California limited liability company; and DOES 1 through 25, inclusive,
Defendants.

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:

CALDERWOOD & HARKNESS LLP

HARGROVE, PETTIT & SUN LLP

IT IS SO ORDERED.

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