Case 1:07-cv-00570-SLR
Document 15
Filed 04/15/2008
Page 1 of 2
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE DEAN REYES, Plaintiff, v. PERDUE FARMS INCORPORATED, a Maryland corporation, Defendant. ) ) ) ) ) ) ) ) )
C.A. No. 07-570 SLR
STIPULATION OF SETTLEMENT AND DISMISSAL WHEREAS, on September 20, 2007 Plaintiff Dean Reyes commenced the above action against Defendant Perdue Farms Incorporated in the United States District Court for the District of Delaware alleging violations of the Family and Medical Leave Act (FMLA), 29 U.S.C. ยง 2601 et seq., and asserting various state law claims; and WHEREAS, Defendant answered the complaint denying all the material allegations contained therein; and WHEREAS, the Defendant and Plaintiff have reached a written agreement as to the complete and final settlement of this litigation, including, but not limited to, a release of all claims brought under the FMLA against the Defendant; IT IS HEREBY STIPULATED by and between the parties through their respective counsel that the above-captioned action shall be dismissed with prejudice, and that Plaintiff hereby releases Defendant from any and all claims he has or may have under the FMLA; and
DB02:6740218.1
066825.1003
Case 1:07-cv-00570-SLR
Document 15
Filed 04/15/2008
Page 2 of 2
IT IS FURTHER STIPULATED that with Plaintiff and Defendant shall bear their own respective costs and attorneys' fees.
SCHMITTINGER & RODRIGUEZ, P.A.
YOUNG CONAWAY STARGATT & TAYLOR, LLP
____/s/_________________________ Noel E. Primos, Esquire (No. 3124) 414 S. State Street P.O. Box 497 Dover, DE 19903 (302) 674-0140 Attorneys for Plaintiff
____/s/_________________________ Scott A. Holt (No. 3399) The Brandywine Building, 17th Floor 1000 West Street Wilmington, Delaware 19801 (302) 571-6623 [email protected] Attorneys for Defendant
SO ORDERED AND APPROVED this ___ day of ____________ 2008,
________________________________
Judge Susan L. Robinson
DB02:6740218.1
066825.1003