Free Motion to Dismiss - District Court of California - California

Case 3:07-cv-02396-IEG-WMC

Document 18

Filed 04/03/2008

Page 1 of 3

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II

Amy B. Vandeveld,

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3 4

II

LAW OFFICES OF AMY B. VANDEVELD 1850 Fifth Avenue, Suite 22
San Diego, California 92101

SBN 137904

II

Telephone:
Facsimile: Attorney

(619) 231-8883
(619) 231-8329

for KAREL SPIKES

5 6 7 IN THE UNITED STATES DISTRICT COURT

8
SOUTHERN DISTRICT OF CALIFORNIA

9 10
11 12 13 vs. JD COLLISION CENTER, MD AUTO REPAIR & TIRES and PRECISION MOTORS; JAMACHA ROAD ASSOCIATES, LLC and DOES 1 THROUGH 10, Inclusive, Defendants. KAREL SPIKES, Plaintiff, JOINT MOTION DISMISSAL FOR Case No.: 07 cv 2396 lEG (WMc)

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[F.R.Civ.P. Rule 41 (a) (1), (2)]

IT IS HEREBY STIPULATED by and between KAREL SPIKES, Plaintiff, on the one hand, and JD COLLISION CENTER, MD AUTO REPAIR & TIRES and PRECISION MOTORS and JAMACHA ROAD ASSOCIATES,
LLC, Defendants, on the other hand, attorneys (hereinafter "the Parties")

through their respective have agreed to resolve settlement.

of record that said Parties them by way of

the case between

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26 27 28

The Parties further stipulatethat Magistrate Judge William
McCurine, or any other Magistrate Judge appointed by the Court, the Parties but not

shall retain jurisdiction

over all disputes Agreement

between

arising out of the Settlement

including,

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03/25/2008 14:05 ea/25/2eea 12:13
~.

Case 3:07-cv-02396-IEG-WMC
6192321859 1

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Filed 04/03/2008

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PAGE PtIGE 03 03/03

ROSENBERG SHPALL VANDEVEL.IE~

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limited to, interpretat10n Settlement Agreement.

and enforcQMent

of the ter.ms of the Agreement are

The terms of the Settlement

hereby incorporated The Parties

in this Joint Motion stipulate,

for Dismissal. to F8de~al Rules of

4

further

pursuant

5 Ci~il Pr~cedure
6 7 8 9 10

41(a) (1,2), that this Court enter a dismissal of

Plaintiff's Complaint in USPC C~se No. 07 cv 2396 IEG (WMc) in its entiz'etyand with prejudice. The Parties further stipulate

that eact shall bear its, his or her Own costs and fees ~ith ~espect tQ any claims they may have against each other in the

instant action, except as otherwise set forth in the Settlement Agreement.

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n

:ts SO snPtJt.M'SD.
LAW OFFICES OF AMY B. VANDEVELP

I DATED: _

S/Am~B. Vand~ve~d AMY B. VANDEVE~D, Attorney for Plaintiff E-mail: [email protected]

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22 23 24 2S

I DA'1'J::D:

By:

A

T as
or

JD otLISION CNETER, MD AUTO REPAIR & TIRES and PRECISION MOTORS LAW OFFICES OF F. SIGMUND LUTHER

=
2

Schpal1, ~sq. for Defendants

261 DATED:
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By:

'lIetW.J11. ~~JJa.'L,

Esq.

Atto~ney fo~ Defendant JAMACHA ROAD ASSOCIATES,

LtC

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-. . Case 3:07-cv-02396-IEG-WMC

Document 18

Filed 04/03/2008

Page 3 of 3
P.03/03-.

APR-02-2008

12:22

619 239 0541

111 limited to,

in:t,erpretation

and enforcement
The terms

of the

terms

of the
are

2 Settlement Agreement. 3 hereby incorporated 4 5 6
7 8 9 10
Ci~il fhe Parties

of the Settlement Motion

Agreement

in this

Joint

for Dismissal. to Federal enter Rules of of

further 41(a)

stipulate,

pursuant this Court

Procedure

(1,2), that in USDC

a dismissal IEG (WHc) in stipulate

~laintiffts its entirety

Complaint and ~ith

Case No. The

07 cv 2396 ~arties

prejudice.

further

that each shall bear its, his or her own costs and fees with

respect to any claims they may have against each other in the
instant action, except as otherwise set forth in the Settlement

11 " Agreement. 12 13 14 15 16 17
DATED: tAW OFFICES OF AMY B. VANDEVELD

_

S/Am~ B. Vandeveld AMY B. VANDEVELD, At~orney for Plaintiff E-mail: [email protected]

18 19 20 21 DATED: 22 23 24 2S 26 27 28 2
TOTAL P.03
DATED: !:/.. 2-/ /

ROSENBERG

5CHPALL

& ASSOCIATES

_

By:

TOMAS A. SCHPAtL, Esq. Attorney for Defendants
JD COLLISION CENTER, MD AUTO & TIRES and PRECISION MOTORS LAW OFFICES OF F. SIGMUND RE~AIR

LUTHER

0 K'
Attorney for Defendant JAMACHA ROAD ASSOCIATES,

F_~i~,

Esq.,
LtC

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