Mesa RHF Partners, LP v. City of Los Angeles
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The Court of Appeal affirmed the trial court's orders denying Mesa, Hill, and Olive's motions to enforce settlement agreements under Code of Civil Procedure section 664.6. Although the trial court denied the motions on the merits, the court held that the trial court lacked jurisdiction to hear the motions because Mesa, Hill, and Olive's requests for dismissal were not section 664.6 requests for the trial court to retain jurisdiction. In this case, the requests for dismissal were not signed by the "parties" as that term in section 664.6 has been uniformly construed by California courts.
The court noted that the parties could have easily invoked section 664.6 by filing a stipulation and proposed order either attaching a copy of the settlement agreement and requesting that the trial court retain jurisdiction under section 664.6 or a stipulation and proposed order signed by the parties noting the settlement and requesting that the trial court retain jurisdiction under section 664.6.
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