Stipulation and Proposed Order for Dismissal and Retention of Jurisdiction between Westgate Entertainment Corporation, Weyland & Chase Engineering, NV, and RMS Titanic, Inc.

Contract Categories: Business Operations › Settlement Agreements
Summary

Westgate Entertainment Corporation, Weyland & Chase Engineering, NV, and RMS Titanic, Inc. have agreed to settle their legal dispute. This document is a joint request to the court to dismiss the case permanently, while allowing the court to keep authority to enforce the terms of their settlement agreement. Both parties' attorneys have signed the stipulation, and the order awaits the judge's approval.

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EX-10.2 4 ex10-2.txt FORM OF STIPULATION AND (PROPOSED) ORDER GREENBERG TRAURIG, LLP MATTHEW S. STEINBERG (Sbn 82969) JORDAN D. GROTZINGER (sbn 190166) 2450 Colorado Avenue, Suite 400E Santa Monica, California 90404 Telephone: (310) 586-7700 Facsimile: (310) 586-7800 Attorneys for Plaintiffs Westgate Entertainment Corporation and Weyland & Chase Engineering, NV UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA WESTGATE ENTERTAINMENT CORPORATION, et al., CASE NO. CV-01-04894 FMC (MANx) Plaintiffs, STIPULATION AND [PROPOSED] ORDER FOR DISMISSAL OF ACTION AND RETENTION OF JURISDICTION vs. Hon. Florence Marie Cooper RMS TITANIC, INC., et al., Defendants. The parties, having entered into a written agreement providing for the settlement of this action, hereby stipulate and agree that pursuant to Rule 41(a)(1)(ii) of the Federal Rules of Civil Procedure, this action shall be dismissed with prejudice, except that the Court shall retain exclusive jurisdiction to enforce the Settlement Agreement, a true copy of which is attached hereto as Exhibit 1. Dated: _______, 2002 GREENBERG TRAURIG, LLP By:________________________________ MATTHEW S. STEINBERG Attorneys for John Joslyn, Westgate Entertainment Corporation and Weyland & Chase Engineering, NV Dated: _______, 2002 MARTORELLA & ASSOCIATES By:________________________________ DANIEL A. MARTORELLA Attorneys for RMS Titanic, Inc. and Arnie Geller IT IS SO ORDERED. Dated: _______, 2002 ----------------------------------- UNITED STATES DISTRICT JUDGE