Joe Hand Promotions, Inc. v. Khinda et al

Filing 16

STIPULATION and ORDER signed by Judge William B. Shubb on 1/13/12 DISMISSING action without prejudice. IT IS FURTHER ORDERED that provided no party referenced has filed a motion to reopen this action by 2/5/12, the dismissal shall be deemed to be with prejudice. (Meuleman, A)

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Thomas P. Riley, SBN 194706
LAW OFFICES OF THOMAS P. RILEY, P.C.
First Library Square
1114 Fremont Avenue
South Pasadena, CA 91030-3227
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff
Joe Hand Promotions, Inc.

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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JOE HAND PROMOTIONS, INC.,

CASE NO. 2:10-cv-02104-WBS-EFB

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Plaintiff,

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vs.

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AMARJIT SINGH KHINDA, ET AL.,

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Defendants.
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STIPULATION OF DISMISSAL OF
PLAINTIFF’S COMPLAINT AGAINST
DEFENDANTS AMARJIT SINGH KHINDA
AND HARDEV KHINDA, individually and
d/b/a TEXAS BUFFALO WINGS AND
TEXAS BUFFALO WINGS, INC., an
unknown business entity, d/b/a TEXAS
BUFFALO WINGS

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IT IS HEREBY STIPULATED by and between Plaintiff JOE HAND PROMOTIONS, INC.

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and Defendants AMARJIT SINGH KHINDA AND HARDEV KHINDA, INDIVIDUALLY and

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d/b/a TEXAS BUFFALO WINGS AND TEXAS BUFFALO WINGS, INC., an unknown business
entity, d/b/a TEXAS BUFFALO WINGS that the above-entitled action is hereby dismissed
without

prejudice

against

AMARJIT

SINGH

KHINDA

AND

HARDEV

KHINDA,

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INDIVIDUALLY and d/b/a TEXAS BUFFALO WINGS AND TEXAS BUFFALO WINGS, INC.,
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an unknown business entity, d/b/a TEXAS BUFFALO WINGS.
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IT IS FURTHER STIPULATED that provided no Party referenced above has filed a
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motion to reopen this action by February 5, 2012, the dismissal shall be deemed to be with
prejudice.
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STIPULATION OF DISMISSAL
Case No. 2:10-cv-02104-WBS-EFB
PAGE 1

This dismissal is made pursuant to Federal Rules of Civil Procedure 41(a)(1). Each Party

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referenced-above shall bear its own attorneys’ fees and costs.

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Dated: January 11, 2012

/s/ Thomas P. Riley
LAW OFFICES OF THOMAS P. RILEY, P.C.
By: Thomas P. Riley
Attorneys for Plaintiff
JOE HAND PROMOTIONS, INC.

Dated:

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/s/ Bruce C. Piontkowski
TINGLEY PIONTKOWSKI, LLP
By: Bruce C. Piontkowski, Esquire
Attorney for Defendants AMARJIT SINGH KHINDA
AND HARDEV KHINDA, individually
and d/b/a TEXAS BUFFALO WINGS and
TEXAS BUFFALO WINGS, INC., an unknown
business entity, d/b/a TEXAS BUFFALO WINGS

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IT IS SO ORDERED:

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DATED: January 13, 2012
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STIPULATION OF DISMISSAL
Case No. 2:10-cv-02104-WBS-EFB
PAGE 2

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PROOF OF SERVICE (SERVICE BY OVERNIGHT MAIL)

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I declare that:
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I am employed in the County of Los Angeles, California. I am over the age of eighteen years
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and not a party to the within cause; my business address is First Library Square, 1114 Fremont Avenue,
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South Pasadena, California 91030. I am readily familiar with this law firm's practice for collection and
processing of correspondence/documents for mail in the ordinary course of business.

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On January 11, 2012, I served:

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STIPULATION OF DISMISSAL OF PLAINTIFF’S COMPLAINT AGAINST
DEFENDANTS AMARJIT SINGH KHINDA AND HARDEV KHINDA, individually
and d/b/a TEXAS BUFFALO WINGS AND TEXAS BUFFALO WINGS, INC., an
unknown business entity, d/b/a TEXAS BUFFALO WINGS

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On all parties referenced by enclosing a true copy thereof in a sealed envelope with postage

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prepaid and following ordinary business practices, said envelope was duly mailed and addressed to:

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Mr. Bruce Piontkowski, Esquire
TINGLEY PIONTKOWSKI, LLP
10 Almaden Blvd., Suite 430
San Jose, CA 95113

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I declare under the penalty of perjury pursuant to the laws of the United States that the
foregoing is true and correct and that this declaration was executed on January 11, 2012, at South
Pasadena, California.

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Dated: January 11, 2012

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STIPULATION OF DISMISSAL
Case No. 2:10-cv-02104-WBS-EFB
PAGE 3

/s/Maria Baird
MARIA BAIRD