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Pursuant to CRC 2.9(e(1 this document has been electronically filed by the Superior Court of California, County of Santa Barbara, on 3/3/20 1 NINA J. BAUMLER, ESQ. (SBN 67 THE LAW OFFICE OF NINA BAUMLER 2 840 Apollo Street, Suite 3 El Segundo, CA 905 3 Telephone: (4 9-06 4 Email: nina@baumlerlaw.com 5 Attorney for Plaintiffs Baby Dennis Salcedo and Dominador Elizaga 6 ANDREW MANSFIELD, ESQ. (SBN 4556 MANSFIELD LAW CORPORATION 7 75 N. Ventura Rd., Suite 201 8 Oxnard, CA 93036 Telephone: (805 642-6406 9 Email: amansfield@mcpclawfirm.com Attorneys for Plaintiffs Comforts of Home Senior Care, Inc., Trina Dellinger-Gleissner and Gary Gleissner 16 20 BABY DENNIS SALCEDO and DOMINADOR ELIZAGA, SUPERIOR COURT OF THE STATE OF CALIFORNIA v. COMFORTS OF HOME SENIOR CARE, INC. and TRINA DELLINGER-GLEISSNER and GARY GLEISSNER and DOES 1-0 INCLUSIVE, Defendants. COUNTY OF SANTA BARBARA ANACAP A DIVISION Plaintiffs, ------------------------------------------------------------- CASE NO: 16CV02077 Department: Judge: Complaint filed: Trial date: JOINT STIPULATION TO SETTLEMENT, DISMISSAL AND CONTINUING JURISDICTION OF COURT UNDER CCP 664.6; PROPOSED ORDER -1- STIPULATION TO SETTLEMENT UNDER CCP 664.6 Salcedo et al v. Comforts of Home Senior Care, Inc. et al, 16CV02077 5 Hon. Colleen K. Sterne May, 2016 April, 20

I. FACTUAL BACKGROUND 2 1. On May, 2016, Plaintiffs filed this action against Defendants. 3 2. On February, 20, Plaintiffs Baby Dennis Salcedo and Dominador Elizaga, and 4 Defendants Comforts of Home Senior Care, Inc., Trina Dellinger-Gleissner and Gary Gleissner ("the 5 Parties" entered into a confidential settlement agreement ("Settlement Agreement" providing for 6 mutual releases, dismissal of the action, payments over the course of 50 months and retention of 7 jurisdiction by the Court pursuant to Civil Code of Procedure Section 664.6. 8 3. The Settlement Agreement also provided for Court approval of settlement of the third cause of 9 action based upon the Private Attorney General Act of 2004. II. STIPULATION REGARDING DISMISSAL AND CONTINUING JURISDICTION OF THE COURT The Parties to this action hereby stipulate to settlement, dismissal and continuing jurisdiction of the Court under CCP 664.6, as follows: 1. Within seven days of receipt of the sums due pursuant to clauses 2(A and 3 of the Settlement Agreement, and the Court's approval of settlement of the third cause of action based upon the Private 16 Attorney General Act of 2004, Plaintiffs shall dismiss the entire action and all parties, except to the extent necessary for the Court to maintain jurisdiction to enforce the terms of the settlement agreement under CCP 664.6. Ill 20 Ill Ill Ill Ill Ill Ill -2- STIPULATION TO SETILEMENT UNDER CCP 664.6 Salcedo et al v. Comforts of Home Senior Care, Inc. et al, 16CV02077

- ' -- 2. If any party fails to comply with its obligations under the Settlement Agreement> the parties 2 hereby stipulate that judgment may be entered against such party or parties in accordance with the 3 terms of the Settlement Agreement. 4 5 SO STIPULATED. 6 7 laintlff aby 8 ated:- - /? 9 Nina Baumler, ESq., Attorney for Plaintiffs Baby Dennis Salcedo and Dominador Elizaga Dated: 3 { 1 { 1 ~ laintiff'dojr ated: 2/n/1r- Elizaga efendant Trina Dellinger-Gleissner Andrew MansfielCl, Esq., Attorney for Defendants Comforts of Home Senior Care, Inc., Trina Dellinger-Gleissner and Gary Gleissner Dated: ------- 16,.,,,.,,,_~~----~~~-- efendant Gary Gleissncr 20 efenc!ant Comforts of Home Senior Care, Inc. y its CEO Trina Dellinger-Gleissner -3- STIPULATION TO SET'ILEMENT UNDER CCP 664.6 Salcedo et al v. Comforts of Home Senior Caret Inc. et al, 16CV02077

2. If any party fails to comply with its obligilti~ns under the Settlement Agreement, the parties 2 hereby stipulate that judgment may be entered against such party or parties in accordance with the: 3 terms.of the Settlement Agreement. 4 s 6 SO STIPULATED... Nina Baumler, Esq., Attorney fur Plaintiffs. Baby Dennis Salcedo and Domjnador Elizaga Dated: -----... iaintifi'&minador Eliilga : ~erfordefendanw Comforts of Honie Senior Cate,.Inc., Trina. Delli1'ger-Gleis.sner and Gary Gl~issner Dated: ~ -:2. I ~.. STIPULATION to SBTTLEMENT UNDER CCP 664.6.. Salcedo ct al v, Comforts of Ho~ S~or Clre, In~. et al, 16CV020'

1 2 [PROPOSED ORDER] Based on the foregoing stipulation and for good cause shown, the Court hereby vacates all 3 dates in this action, including all motion hearing dates, pre-trial and trial dates, and sets an Order to 4 Show Cause Re: Dismissal for, 20. 5 Notwithstanding any dismissal of the action, the Court maintains jurisdiction over this matter 6 and the Parties under CCP 664.6 for the purpose of enforcing the terms of the settlement agreement. 7 8 9 16 20 DATED: IT IS SO ORDERED, Hon. Colleen K. Sterne Judge of the Superior Court -1- PROPOSED ORDER Salcedo et al v. Comforts of Home Senior Care, Inc. et al, 16CV02077

1 2 3 4 5 6 7 8 9 16 20 PROOF OF SERVICE Case No: 16CV02077 I am employed in the County of Los Angeles, my business address is 840 Apollo Street, Suite 3, El Segundo, CA 905. I am over the age of and not a party to the foregoing action. I am readily familiar with the business practice at my place of business for collection and processing of correspondence for personal delivery, for mailing with United States Postal Service, for facsimile, and for overnight delivery by Federal Express, Express Mail, or other overnight service. On March 3, 20, I caused a copy of the following document(s: JOINT STIPULATION TO SETTLEMENT, DISMISSAL AND CONTINUING JURISDICTION OF COURT UNDER CCP 664.6; PROPOSED ORDER to be served on the interested parties in this action by placing a true and correct copy thereof, enclosed in a sealed envelope, and addressed as follows: ANDREW S. MANSFIELD MANSFIELD LAW CORPORATION 75 N. Ventura Rd., Ste. 201 Oxnard, CA 93036 X MAIL: Such correspondence was deposited, postage fully paid, with the United States Postal Service on the same day in the ordinary course of business. PERSONAL: FACSIMILE: Such envelope was delivered by hand to the offices of the addressee. Such document was faxed to the facsimile transmission machine with the facsimile machine number stated above. Upon completion of the transmission, the transmitting machine issued a transmission report showing the transmission was complete and without error. I declare under penalty of perjury that the above is true and correct. Executed on March 3, 20 at El Segundo, California. /S/ Nina Baumler PROOF OF SERVICE