Stipulated Settlement Agreement Sample Contracts

STIPULATED SETTLEMENT AGREEMENT
Stipulated Settlement Agreement • August 18th, 2020

WHEREAS, on July 15, 2015, the Center for Biological Diversity, Humane Society International, Humane Society of the United States, Born Free USA, and the International Fund for Animal Welfare submitted a petition requesting that the Service issue a rule pursuant to Section 4(e) of the ESA, 16 U.S.C. § 1533(e), ("4(e) petition") to treat the seven pangolin species as endangered species based on their similarity of appearance to the ESA listed Temminck's ground pangolin (Manis temminckii);

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STIPULATED SETTLEMENT AGREEMENT
Stipulated Settlement Agreement • December 21st, 2018

This Stipulated Settlement Agreement (Agreement) is entered into by and between Friends of Animals and the Audubon Society of Greater Denver (collectively, FOA) and Center for Biological Diversity (CBD) (collectively, Petitioners) and the United States Fish and Wildlife Service (Service), Jim Kurth, in his official capacity as Acting Director of the Service, and Ryan Zinke, in his official capacity as Secretary of the Interior (collectively, Respondents), who, by and through their undersigned counsel, state as follows:

STIPULATED SETTLEMENT AGREEMENT
Stipulated Settlement Agreement • March 17th, 2022

This Stipulated Settlement Agreement (“Agreement”) is entered into by and between Plaintiffs Wildearth Guardians and Physicians for Social Responsibility, and Federal Defendants Debra Haaland, in her official capacity as Secretary of the U.S. Department of the Interior; Tracy Stone-Manning, in her official capacity as Director of the Bureau of Land Management; and the Bureau of Land Management (“BLM”), who, by and through their undersigned counsel (collectively “the Parties”), state as follows:

STIPULATED SETTLEMENT AGREEMENT
Stipulated Settlement Agreement • May 5th, 2020

This Stipulated Settlement Agreement (“Agreement”) is entered into by and between the Plaintiff Center for Biological Diversity (“Center”) and Defendants Ken Salazar, in his official capacity as Secretary of the Interior; Rowan Gould, in his official capacity as Acting Director of the U.S. Fish and Wildlife Service (“Service” or “FWS”); and the Service (collectively, “Defendants”), (collectively, the “Parties”), who state as follows:

STIPULATED SETTLEMENT AGREEMENT
Stipulated Settlement Agreement • February 10th, 2022

Plaintiff the Center for Biological Diversity and Defendants S.M.R. Jewell, in her official capacity as Secretary of the United States Department of the Interior, and the United States Fish and Wildlife Service (“Service”) (“Defendants”) and collectively referred to as “the Parties” who, by and through their undersigned counsel, state as follows:

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
Stipulated Settlement Agreement • October 13th, 2020

WHEREAS, the United States brought the above-captioned action (the “Action”) to enforce provisions of the Fair Housing Act (“FHA”), codified at 42 U.S.C. §§ 3601–3619. Specifically, the United States’ Complaint alleges that Atlantic has violated the Fair Housing Act by failing to design and construct 33 West End with the features of accessible and adaptive design and construction required by the FHA, see 42 U.S.C. § 3604(f)(3)(C);

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS
Stipulated Settlement Agreement • November 29th, 2021

NATIONAL ASSOCIATION OF CONSUMER ADVOCATES, et al., Plaintiffs, v. Civil Action No. 1:20-cv-11141-JCB ROHIT CHOPRA, in his official capacity as Director of the Consumer Financial Protection Bureau, et al., Defendants.

Contract
Stipulated Settlement Agreement • April 14th, 2022
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Stipulated Settlement Agreement • September 23rd, 2013

This Stipulated Settlement Agreement (“Agreement”) is entered into by and between Plaintiff Center for Biological Diversity (“Center”) and Defendants S. M. R. Jewell, in her official capacity as Secretary of the United States Department of the Interior; and the United States Fish and Wildlife Service (“Service”) (collectively, “Defendants”), who, by and through their undersigned counsel, state as follows:

STIPULATED SETTLEMENT AGREEMENT
Stipulated Settlement Agreement • March 3rd, 2022

This Stipulated Settlement Agreement (“Agreement”) is entered into by and between Plaintiffs Wildearth Guardians and Physicians for Social Responsibility, and Federal Defendants Debra Haaland, in her official capacity as Secretary of the U.S. Department of the Interior; Tracy Stone-Manning, in her official capacity as Director of the Bureau of Land Management; and the Bureau of Land Management (“BLM”), who, by and through their undersigned counsel (collectively “the Parties”), state as follows:

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO
Stipulated Settlement Agreement • November 29th, 2012
UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA
Stipulated Settlement Agreement • May 31st, 2022

This Stipulated Settlement Agreement (“Agreement”) is entered into by and between Plaintiffs Center for Biological Diversity (“Center”), Humane Society International, and the Humane Society of the United States (collectively, “Plaintiffs”) and Defendants Debra Haaland, in her official capacity as Secretary of the United States Department of the Interior (“Interior”), and the United States Fish and Wildlife Service (“Service”) (collectively, “Defendants”), who, by and through their undersigned counsel, state as follows:

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Stipulated Settlement Agreement • February 16th, 2021

This Stipulated Settlement Agreement (“Agreement”) is entered into by and between Plaintiffs Center for Biological Diversity, Tropical Audubon Society, and North American Butterfly Association Chapter of South Florida, Inc. d/b/a/ Miami Blue Chapter (“Plaintiffs”) and Defendants David Bernhardt, in his official capacity as Secretary of the U.S. Department of the Interior, the U.S. Department of the Interior, and Aurelia Skipwith in her official capacity as Director of the U.S. Fish and Wildlife Service (“Service” or “FWS”) (collectively, “parties”), who, by and through their undersigned counsel, state as follows:

STIPULATED SETTLEMENT AGREEMENT
Stipulated Settlement Agreement • September 25th, 2019

This Stipulated Settlement Agreement (Agreement) is entered into by and between Plaintiff Natural Resources Defense Council, Inc. and Defendants David L. Bernhardt, et al. (collectively, the Parties), who, by and through their undersigned counsel, state as follows:

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Stipulated Settlement Agreement • July 24th, 2023

This Stipulated Settlement Agreement (“Agreement”) is entered into by and between Plaintiff Center for Biological Diversity (“Center”) and Defendants United States Fish and Wildlife Service (“FWS”); Debra Haaland, in her official capacity as Secretary of the United States Department of Interior; and Martha Williams, in her official capacity as Director of FWS, (collectively, “Defendants”), who, by and through their undersigned counsel, state as follows:

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Stipulated Settlement Agreement • October 10th, 2019

This Stipulated Settlement Agreement (“Agreement”) is entered into by and between Plaintiff Center for Biological Diversity (“Center”) and Defendants David Bernhardt, in his official capacity as Secretary of the United States Department of the Interior (“Interior”), and the United States Fish and Wildlife Service (“Service”) (collectively, “Defendants”), who, by and through their undersigned counsel, state as follows:

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Stipulated Settlement Agreement • April 25th, 2021

This Stipulated Settlement Agreement (“Agreement”) is entered into by and between Plaintiff Center for Biological Diversity (“Center”), Plaintiff Greenpeace, Inc., and Plaintiff The Boat Company (“Plaintiffs”); and Defendants S. M. R. Jewell, in her official capacity as Secretary of the United States Department of the Interior; and the United States Fish and Wildlife Service (“Service”) (collectively, “Defendants”), who, by and through their undersigned counsel, state as follows:

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Stipulated Settlement Agreement • August 14th, 2020

WHEREAS, on July 15, 2015, the Center for Biological Diversity, Humane Society International, Humane Society of the United States, Born Free USA, and the International Fund for Animal Welfare submitted a petition requesting that the Service issue a rule pursuant to Section 4(e) of the ESA, 16 U.S.C. § 1533(e), (“4(e) petition”) to treat the seven pangolin species as endangered species based on their similarity of appearance to the ESA listed Temminck’s ground pangolin (Manis temminckii);

Contract
Stipulated Settlement Agreement • September 12th, 2023
STIPULATED SETTLEMENT AGREEMENT
Stipulated Settlement Agreement • March 3rd, 2022

This Stipulated Settlement Agreement (“Agreement”) is entered into by and between Plaintiffs Wildearth Guardians and Physicians for Social Responsibility, and Federal Defendants Debra Haaland, in her official capacity as Secretary of the U.S. Department of the Interior; Tracy Stone-Manning, in her official capacity as Director of the Bureau of Land Management; and the Bureau of Land Management (“BLM”), who, by and through their undersigned counsel (collectively “the Parties”), state as follows:

Stipulated Settlement Agreement
Stipulated Settlement Agreement • August 4th, 2009

It is hereby stipulated between Plaintiffs Mohammed Saleh, El Sayyid Nosair, and Ibrahim Elgabrowny ("Plaintiffs") and Defendants the Federal Bureau of Prisons, Michael Mukasey, Harley Lappin, Joyce K. Conley, Michael Nalley, Ron Wiley, and Michael Merrill ("Defendants"), through their respective attorneys, as follows:

STIPULATION OF SETTLEMENT
Stipulated Settlement Agreement • September 23rd, 2019

This stipulated Settlement Agreement dated September 23, 2019 (the “Stipulation” or the “Settlement Agreement”) embodies a settlement (the “Settlement”) made and entered into by and among the following Settling Parties: (i) Plumbers and Pipefitters National Pension Fund (“Plumbers and Pipefitters”), United Association Local Union Officers & Employees’ Pension Fund (the “UA Fund”), and the Department of the Treasury of the State of New Jersey and its Division of Investment (“New Jersey”) (collectively, Plumbers and Pipefitters, the UA Fund, and New Jersey are hereinafter referred to as “Lead Plaintiffs” or “Plaintiffs”), on behalf of themselves and each of the Class Members, and (ii) Defendants Trinity Industries, Inc. (“Trinity” or the “Company”), Timothy R. Wallace, James E. Perry, and Gregory B. Mitchell (collectively, “Defendants”), by and through their counsel of record in the above-captioned consolidated litigation (the “Action”) pending in the United States District Court for the

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STIPULATED SETTLEMENT AGREEMENT AND STIPULATION FOR DISMISSAL
Stipulated Settlement Agreement • September 11th, 2023

WISCONSIN STATE JOURNAL, et al., Plaintiffs, v. EDWARD A. BLAZEL, in his official capacity as Assembly Chief Clerk, et al., Defendants. Case No. 2020-CV-764

Stipulated Settlement Agreement Finn, et al. v. Cobb County Board of Elections and Registration, et al. US District Court N. D. Ga. CAF 1:22-cv-2300
Stipulated Settlement Agreement • October 28th, 2023

between Plaintiffs Karen Finn, Dr. Jillian Ford, Hylah Daly, Jenne Dulcio, GALEO Latino Community Development Fund, Inc., New Georgia Project Action Fund, League of Women Voters of Marietta-Cobb, and Georgia Coalition for the People’s Agenda, Inc. (the “Plaintiffs”) and Defendants Cobb County Board of Elections and

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Stipulated Settlement Agreement • September 22nd, 2014

This Stipulated Settlement Agreement (“Agreement”) is entered into by and between Plaintiff Center for Biological Diversity (“Center”) and Defendants S. M. R. Jewell, in her official capacity as Secretary of the United States Department of the Interior; and the United States Fish and Wildlife Service (“Service”) (collectively, “Defendants”), who, by and through their undersigned counsel, state as follows:

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
Stipulated Settlement Agreement • October 13th, 2020

WHEREAS, the United States brought the above-captioned action (the “Action”) to enforce provisions of the Fair Housing Act (“FHA”), codified at 42 U.S.C. §§ 3601–3619. Specifically, the United States’ Complaint alleges that Atlantic has violated the Fair Housing Act by failing to design and construct 33 West End with the features of accessible and adaptive design and construction required by the FHA, see 42 U.S.C. § 3604(f)(3)(C);

STATE OF FLORIDA
Stipulated Settlement Agreement • May 16th, 2011
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Stipulated Settlement Agreement • December 13th, 2023
STIPULATED SETTLEMENT AGREEMENT
Stipulated Settlement Agreement • September 9th, 2015

This Stipulated Settlement Agreement (“Agreement”) is entered into by and between Plaintiff Center for Biological Diversity (“Center”) and Defendants S. M. R. Jewell, in her official capacity as Secretary of the United States Department of the Interior; and the United States Fish and Wildlife Service (“Service”) (collectively, “Defendants”), who, by and through their undersigned counsel, state as follows:

STIPULATION OF SETTLEMENT
Stipulated Settlement Agreement • September 23rd, 2019

This stipulated Settlement Agreement dated September 23, 2019 (the “Stipulation” or the “Settlement Agreement”) embodies a settlement (the “Settlement”) made and entered into by and among the following Settling Parties: (i) Plumbers and Pipefitters National Pension Fund (“Plumbers and Pipefitters”), United Association Local Union Officers & Employees’ Pension Fund (the “UA Fund”), and the Department of the Treasury of the State of New Jersey and its Division of Investment (“New Jersey”) (collectively, Plumbers and Pipefitters, the UA Fund, and New Jersey are hereinafter referred to as “Lead Plaintiffs” or “Plaintiffs”), on behalf of themselves and each of the Class Members, and (ii) Defendants Trinity Industries, Inc. (“Trinity” or the “Company”), Timothy R. Wallace, James E. Perry, and Gregory B. Mitchell (collectively, “Defendants”), by and through their counsel of record in the above-captioned consolidated litigation (the “Action”) pending in the United States District Court for the

Contract
Stipulated Settlement Agreement • July 12th, 2023 • California
STIPULATED SETTLEMENT AGREEMENT
Stipulated Settlement Agreement • December 9th, 2020

This Stipulated Settlement Agreement (“Agreement”) is entered into by and between Plaintiff Center for Biological Diversity and Defendants David Bernhardt, in his official capacity as Secretary of the United States Department of the Interior, and the United States Fish and Wildlife Service (“Service”) (collectively, “Defendants”) who, by and through their undersigned counsel, state as follows:

STIPULATED SETTLEMENT AGREEMENT AND ORDER
Stipulated Settlement Agreement • August 20th, 2020

This Stipulated Settlement Agreement (“Agreement”) is entered into by and between Plaintiffs Center for Biological Diversity (“Center”), Sea Turtle Oversight Protection, and Turtle Island Restoration Network (collectively “Plaintiffs”), and Defendants David Bernhardt, in his official capacity as Secretary of the U.S. Department of the Interior, Aurelia Skipwith, in her official capacity as Director of the U.S. Fish and Wildlife Service, the U.S. Fish and Wildlife Service (“FWS”), Wilbur Ross, in his official capacity as Secretary of the U.S. Department of Commerce, Chris Oliver, in his official capacity as Assistant Administrator for Fisheries at the National Oceanic Atmospheric Administration (“NOAA”), and the National Marine Fisheries Service (“NMFS”) (collectively “Defendants”), who, by and through their undersigned counsel, state as follows:

STATE OF FLORIDA
Stipulated Settlement Agreement • December 1st, 2016

THIS STIPULATED SETTLEMENT AGREEMENT ("Settlement Agreement") is entered into by and among the State of Florida, Department of Environmental Protection ("DEP"), the Florida Keys Aqueduct Authority ("FKAA"), Monroe County, Florida ("County"), the Cudjoe Gardens Property Owners Association, Inc., and the Sugarloaf Shores Property Owners Association, Inc. (the "POA Petitioners") (collectively, the "Settling Parties"), as a complete and final settlement of all claims raised in the above-styled proceedings.

STATE OF FLORIDA
Stipulated Settlement Agreement • June 16th, 2010

Land Use DU/SF Parking Ratio Required # of spaces Parking Area (SF) Residential 2,960 D.U. 2.5 spaces/unit 7,400 2,590,000 Office 4,588,632 s.f. 1 space/300 s.f. 15295 5,353,404 Retail 850,000 s.f. 1 space/250 s.f. 3,400 1,190,000 Restaurants 150,000 s.f. 1 space/45 s.f.(customer area) 2,667 933,333 Total 28,762 10,066,737 s.f.

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