031124175720 (PDF)

Case 8:15-cv-00996-PSG-JC Document 45 Filed 08/26/16 Page 1 of 3 Page ID #:271

1 LAW OFFICES OF PETER C. CHEN
2 Peter C. Chen, Esq. (SB # 222639)
3
4
5
6

901 Corporate Center Drive
Suite 500
Monterey Park, CA 91754
Telephone: (323) 264-2588
Facsimile: (323) 269-1818
Email:
PChen@lawyer.com
Attorneys for Plaintiffs

7 HEATH & STEINBECK, LLP

STEVEN A. HEATH (SBN 250867)

8 5777 W. Century Blvd., Suite 1670

Los Angeles, CA 90045

9 Telephone: (213) 335-6245

10 Facsimile: (213) 335-6246

saheath@heathsteinbeck.com
11 Attorneys for Defendants
12
13

UNITED STATES DISTRICT COURT

14

CENTRAL DISTRICT OF CALIFORNIA

15

SOUTHERN DIVISION

16
17

JEFFREY LIN, et al.

CASE NO.: 8:15-CV-00996-PSG-JC

Plaintiffs,

18
19

vs.

20

DRAGON GATE OR, LLC, et al.

21
22
23
24

Defendants.

STIPULATION RE DISMISSAL OF
ACTION PURSUANT TO FEDERAL
RULE OF CIVIL PROCEDURE
41(A)(2)
[Proposed Order Lodged Concurrently]
Final Pretrial Conf.: August 29, 2016
Trial Date:
September 13, 2016

25
26
27
28

Plaintiffs JEFFREY LIN, FAN ZHOU, YUE LIN ZHOU, and LI GANG YANG
(“Plaintiffs”) and Defendants DRAGON GATE OR, LLC, XIAO LI, and CHANG XU
CERTIFICATE OF SERVICE

Case 8:15-cv-00996-PSG-JC Document 45 Filed 08/26/16 Page 2 of 3 Page ID #:272

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23

JIANG (“Defendants”), by and through their respective counsel of record, hereby
stipulate and agree as follows:
WHEREAS, on August 25, 2016, the Parties attended mediation and were able to
reach a settlement;
WHEREAS, the written settlement agreement provides for, among other things,
(a) each Party bearing its own attorney’s fees and costs incurred in the above-captioned
matter; (b) payment of a sum certain by Defendants to Plaintiffs over a 25-month period;
and (c) the Court retaining jurisdiction to enforce the settlement agreement;
WHEREAS, pursuant to Federal Rules of Civil Procedure, Rule 41(a)(2), the
Parties respectfully request that the Court enter an order dismissing the case subject to
the provision that the Court retain jurisdiction to enforce the settlement agreement, as
provided above;
NOW, THEREFORE, the Parties hereby stipulate, agree, and respectfully request
that the Court issue an order in the following form:
1. That the present action be dismissed under Federal Rules of Civil Procedure,
Rule 41(a)(2);
2. That each party bears its own attorney fees and costs incurred in the present
action; and
3. That the Court retains jurisdiction to enforce the Parties’ settlement agreement.
IT IS SO STIPULATED.
Dated: August 26, 2016

Respectfully Submitted,
LAW OFFICES OF PETER C. CHEN

24
25
26
27

By: /s/ Peter C. Chen
Peter C. Chen
Attorneys for Plaintiffs
JEFFREY LIN, FAN ZHOU, YUE LIN ZHOU,
and LI GANG YANG

28
CERTIFICATE OF SERVICE

Case 8:15-cv-00996-PSG-JC Document 45 Filed 08/26/16 Page 3 of 3 Page ID #:273

1
2
3
4

Dated: August 26, 2016

Respectfully Submitted,
HEATH & STEINBECK, LLP

5
6
7
8

By: /s/ Steven A. Heath
Steven A. Heath
Attorneys for Defendants DRAGON GATE OR,
LLC, XIAO LI, and CHANG XU JIANG

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
CERTIFICATE OF SERVICE