Stipulation: corporation assumes liability, if any, for subsidiary or related companies in dispute involving current or former employee (state/federal)

[Insert Heading]

STIPULATIONS AS TO FACT AND LAW

TO THE HONORABLE JUDGE OF SAID COURT:

COME NOW [insert Plaintiff] , Plaintiff (hereafter "Plaintiff") and [insert Defendant] , Defendant (hereafter “Defendant”), all parties to this lawsuit and stipulate and agree as follows:

1. [Defendant who first hired Plaintiff] originally hired Plaintiff as an employee.

2. [Defendant successor corp.] is the successor corporation to [Defendant who first hired Plaintiff] .

3. [Defendant successor corp.] assumes all legal liability for any violation of law or wrongs, if any, committed against Plaintiff by [Defendant who first hired Plaintiff] while Plaintiff was employed by [Defendant who first hired Plaintiff] .

4. [Defendant successor corp.] employed Plaintiff as an employee after [Defendant who first hired Plaintiff] ceased to exist.

5. [Defendant successor corp.] fired Plaintiff, its employee, on ______ day of ___________ , 20__.

6. Based upon the representations and agreement that [Defendant successor corp.] has assumed all legal liability for any violation of law or other wrongs, if any, that [Defendant who first hired Plaintiff] committed against Plaintiff, Plaintiff agrees to dismiss [Defendant who first hired Plaintiff] as a Defendant in this lawsuit, without prejudice to the re-filing of said cause of action.

7. [Defendant successor corp.] is an active [state of incorporation] corporation that has been sued in its correct capacity and correct legal name as one of the former employers of Plaintiff.

8. [Defendant successor corp.] agrees not to assert any of the following four defenses: 1) that there is a defect of parties Defendant, whether or not pursuant to Rule [insert applicable state or federal rule, if any] of the Rules of Civil Procedure; 2) that Defendant has not the legal capacity to be sued, whether or not pursuant to Rule [insert applicable state or federal rule, if any,] of...