Lucy H. Koh
KYRA A. KAZANTZIS (STATE BAR NO. 154612)
JAMES F. ZAHRADKA (STATE BAR NO. 196822)
ANNETTE D. KIRKHAM (STATE BAR NO. 217958)
NADIA AZIZ (STATE BAR NO. 252966)
KATHERINE M. LEHE (STATE BAR NO. 273472)
FAIR HOUSING LAW PROJECT
LAW FOUNDATION OF SILICON VALLEY
Attorneys for Plaintiffs DAVID and BARBARA WATTS
STIPULATION FOR DISMISSAL WITH
PREJUDICE AND [PROPOSED] ORDER
The parties have reached a settlement in this matter. Therefore, the parties hereby apply for and stipulate to issuance of an order dismissing this action in its entirety, subject to the terms of the settlement agreement executed' by the parties. Attached as Exhibit A is a redacted version of the Agreement.
The parties request that the Court retain jurisdiction to enforce the Settlement Agreement for 30 days from the execution of the agreement
Respectfully submitted,
FAIR HOUSING LAW PROJECT
________________________
Annette D. Kirkham
Attorneys for Plaintiffs
BRYAN CAVE LLP
________________________
Goli Mahdavi
Attorneys for Defendants, JP MORGAN CHASE BANK, NA,
US BANK NATIONAL ASSOCIATION, and CALIFORNIA
RECONVEYANCE CORPORATION.
ATTESTATION PURSUANT TO GENERAL ORDER 45
I, Annette D. Kirkham, attest that concurrence in the filing of this document has been obtained from each of the signatories. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on August 29, 2012, at San Jose, California.
________________________
Annette D. Kirkham
[PROPOSED] ORDER
Based upon the foregoing application and stipulation and good cause appearing, it is hereby ordered that this action is dismissed in its entirety with prejudice subject to the terms of the settlement agreement executed by the parties. The Court will retain jurisdiction to enforce the settlement agreement for 30 days from the date of the execution of the agreement.
________________________
Honorable Lucy H. Koh
United States District Court Judge