Sergio Perez v. Allscripts Healthcare, LLC et al

Filing 21

ORDER OF PREJUDICIAL DISMISSAL OF ENTIRE LAWSUIT by Judge Andre Birotte Jr. The Stipulation of the parties is hereby accepted and adopted as the order of the court 20 ; all pending litigation events and deadlines, including pretrial conference and trial, are vacated. Case Terminated. Made JS-6. (iv)

JS-6
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JML LAW

A PROFESSIONAL LAW CORPORATION
21052 OXNARD STREET

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WOODLAND HILLS, CALIFORNIA 91367
Tel: [phone]

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Fax: [phone]

JOSEPH M. LOVRETOVICH, STATE BAR NO. 73403
[e-mail]
DAVID F. TIBOR, STATE BAR NO. 230563
[e-mail]
JASON M. YANG, STATE BAR NO. 287311
[e-mail]
Attorneys for Plaintiff
Sergio Perez

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21052 Oxnard Street
Woodland Hills, CA 91367
[phone]

JML LAW

A Professional Law Corporation

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA OF CALIFORNIA

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Case No. 16-CV-06396-AB-E
(Assigned for all purposes to the Hon.
Andre Birotte, Jr.)

SERGIO PEREZ, an individual;
Plaintiff,
vs.

[PROPOSED] ORDER OF
PREJUDICIAL DISMISSAL OF
ENTIRE LAWSUIT

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ALLSCRIPTS HEALTHCARE,
LLC, a North Carolina Limited
Liability Company; and DOES 1
through 50, inclusive;

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Complaint Filed:

July 13, 2016

Defendants.

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It is hereby ordered by United States District Judge André Birotte Jr. as
follows:
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The stipulation of the parties is hereby accepted and adopted as the
order of the court;
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[PROPOSED] ORDER OF PREJUDICIAL DISMISSAL OF ENTIRE
LAWSUIT

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2.

All named and fictitious defendants are hereby dismissed with

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prejudice to re-filing in this or any other federal or state court under

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all pled and unpled causes of action;

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3.

The Plaintiff, SERGIO PEREZ, is permanently waiving all past,

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present and future: special damages, general damages; punitive

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damages; equitable relief, attorneys’ fees, whether of record or not;

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ordinary and extraordinary costs, whether incurred or paid; discovery

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rights; and,

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4.

As a result of the parties’ full and final resolution of all aspects of this

21052 Oxnard Street
Woodland Hills, CA 91367
[phone]

JML LAW

litigation in this or any other federal or state court, as to all pled and

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A Professional Law Corporation

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unpled causes of action in favor of all named or unnamed parties, all

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pending litigation events and deadlines, including the pretrial

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conference and trial, are unnecessary and are forthwith vacated by this

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order.

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IT IS SO ORDERED.

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DATED: April 4, 2017

____________________________________
HONORABLE ANDRÉ BIROTTE JR.

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[PROPOSED] ORDER OF PREJUDICIAL DISMISSAL OF ENTIRE
LAWSUIT

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PROOF OF SERVICE
1013a (3) CCP Revised 5/1/88

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21052 Oxnard Street
Woodland Hills, CA 91367
[phone]

JML LAW

A Professional Law Corporation

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UNITED STATES DISCTRICT COURT CENTRAL DISTRICT OF
CALIFORNIA
I am employed in the County of Los Angeles, State of California. I am over
the age of 18 and not a party to the within action. My business address is, 21052
Oxnard Street, Woodland Hills, CA.91367
On February 15, 2017, I served the foregoing document described as
[PROPOSED] ORDER OF PREJUDICIAL DISMISSAL OF ENTIRE
LAWSUIT, on the interested parties in this action by placing the original true
copies thereof enclosed in a sealed envelope, addressed as follows:
JUDY M. IRIYE
JAMIE CHU
LITTLER MENDELSON, P.C.
2049 Century Park East
5th Floor
Los Angeles, CA 90067-3107
By mail, I deposited such envelope(s) in the mail at Woodland Hills,
California, with postage thereon fully prepaid.
I am readily familiar with the firm's practice of collection and processing
correspondence for mailing. Under that practice it would be deposited with the
U.S. postal service on that same day with postage thereon fully prepaid at
Woodland Hills, California, in the ordinary course of business. I am aware that on
motion of the party served, service is presumed invalid if postal cancellation date
or postage meter date is more than one day after the date of deposit for mailing in
affidavit.
By facsimile, I transmitted such documents from Woodland Hills,
California, to the offices of the addressee(s).
By personal service, I delivered such envelope(s) by hand to the office(s)
of the addressee(s).
(State) I declare under penalty of perjury under the laws of the State of
California that the foregoing is true and correct.
(Federal) I declare that I am employed in the office of a member of the Bar
of this Court, at whose direction the service was made.
Executed on February 15, 2017 at Woodland Hills, California.

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TAD KUCHAR

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[PROPOSED] ORDER OF PREJUDICIAL DISMISSAL OF ENTIRE
LAWSUIT