Tat Tohumculuk A.S. v. H. J. Heinz Company, et al

Filing 63

STIPULATION and ORDER FOR DISMISSAL WITH PREJUDICE 62 signed by Senior Judge William B. Shubb on 4/20/2015. Civil Case Terminated. CASE CLOSED. (Kirksey Smith, K)

Effie F. Anastassiou, Esq. (SBN 96279)
1 ANASTASSIOU & ASSOCIATES
242 Capitol Street
2 Post Office Box 2210
Salinas, California 93902
3 Telephone: [phone]
Facsimile: [phone]
4
Attorneys for Plaintiff,
5 UNITED GENETICS TURKEY TOHUM FIDE A.S.,
formerly known as TAT TOHUMCULUK A. S.
6
7

IN THE UNITED STATES DISTRICT COURT

8

FOR THE EASTERN DISTRICT OF CALIFORNIA,

9
UNITED GENETICS TURKEY TOHUM
10 FIDE A.S., formerly known as TAT
TOHUMCULUK A. S., a Turkish company,
11
Plaintiff,
12
v.
13
H.J. HEINZ COMPANY, L.P., a Pennsylvania
14 Limited Partnership registered to do business
in California, and HEINZSEED, an
15 unincorporated division of H.J. HEINZ
COMPANY, L.P,
16
Defendants.
17
18

CASE NO. 2:13-cv-00773-WBS-KJN
STIPULATED REQUEST FOR
DISMISSAL, WITH PREJUDICE
FED. R. CIV. P. 41(a)(2)

IT IS HEREBY STIPULATED AND AGREED, pursuant to Federal Rules of Civil

19 Procedure, Rule 41(a)(2), by and between each and every party to this stipulation, by and through
20

the signatures of their respective counsel on this stipulation, that the parties to this stipulation wish

21
to formally acknowledge and obtain a court order dismissing the entire instant action, as follows:
22
23

1.

IT IS HEREBY STIPULATED, by and among Plaintiff UNITED GENETICS

24 TURKEY TOHUM FIDE A.S., formerly known as TAT TOHUMCULUK A. S., a Turkish
25 company (“Plaintiff”) and Defendants H.J. HEINZ COMPANY, L.P., a Pennsylvania Limited
26 Partnership registered to do business in California, and HEINZSEED, an unincorporated division
27

of H.J. HEINZ COMPANY, L.P. (“Defendants”) that they are requesting that a Court order be

28
Stipulated Request for Dismissal, with Prejudice

1

entered dismissing, with prejudice, the entire instant action, pursuant to a settlement reached by

2 Plaintiff and Defendants as a result of a successful mediation session.
3

2.

The undersigned represent and warrant that they have all requisite authority to bind

4 the respective parties to the terms of the stipulation.
5
6

3.

This stipulation may be executed in any number of counterparts with the same

effect as if all signatories had signed the same documents. All counterparts must be construed

7
together to constitute one instrument.
8
9

4.

Each party shall bear that party’s own costs and attorneys’ fees in connection with

10 this stipulation.
11

SO STIPULATED.

12 Dated: April 20, 2015
13

ANASTASSIOU & ASSOCIATES
By:

14
15
16

/s/ Effie F. Anastassiou
Effie F. Anastassiou, Esq.
Attorneys for Plaintiff,
UNITED GENETICS TURKEY TOHUM
FIDE A.S., formerly known as TAT
TOHUMCULUK A. S.

17
18
19

Dated: April 20, 2015

GORDON & REES LLP
By:

20
21

/s/ Sean P. Flynn
Sean P. Flynn, Esq.
Attorneys for Defendants,
H.J. HEINZ COMPANY, L.P. and
HEINZSEED, an unincorporated division of
H.J. HEINZ COMPANY, L.P.

22
23
24
25
26
27
28

2
Stipulated Request for Dismissal, with Prejudice

ORDER

1
2

PURSUANT TO STIPULATION, IT IS HEREBY ORDERED that the entire instant

3
action is hereby dismissed, with prejudice.
4
5

SO ORDERED.

6 Dated: April 20, 2015
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

3
Stipulated Request for Dismissal, with Prejudice