Intel Corporation v. Rivers

Filing 92

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr on 1/10/20 DISMISSING this action with prejudice. Each party shall bear its own attorneys' fees and expenses. (Kaminski, H)

1 GREGORY P. STONE (State Bar No. 78329)
[e-mail]
2 JEREMY K. BEECHER (State Bar No. 301272)
[e-mail]
3 MUNGER, TOLLES & OLSON LLP
350 South Grand Avenue, Fiftieth Floor
4 Los Angeles, California 90071-3426
Telephone:
[phone]
5 Facsimile:
[phone]
6 CAROLYN HOECKER LUEDTKE (State Bar No. 207976)
[e-mail]
7 MUNGER, TOLLES & OLSON LLP
560 Mission Street, Twenty-Seventh Floor
8 San Francisco, California 94105
Telephone:
[phone]
9 Facsimile:
[phone]
10 Attorneys for Plaintiff Intel Corporation
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION

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INTEL CORPORATION,
Plaintiff,

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Case No. 2:18-cv-03061-MCE-AC

STIPULATION OF DISMISSAL WITH
PREJUDICE AND ORDER
DISMISSING CASE

vs.

DOYLE RIVERS, an individual, and DOES 1
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Defendant.

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The parties have resolved their dispute and jointly stipulate to the entry of an order

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dismissing this action with prejudice. The parties agree that each will bear its own attorneys’

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fees and expenses. As part of the settlement, Defendant Doyle Rivers has provided a

25 certification that he is currently not in possession of Intel confidential information, that he
26 has not used or disclosed Intel confidential information, and that he will not in the future use
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or disclose Intel confidential information.

The parties have agreed that if it is later

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STIPULATION OF DISMISSAL WITH PREJUDICE and ORDER

1 discovered that this certification is untrue, or if he violates it in the future, that this Court
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shall retain jurisdiction over that dispute and the agreed upon remedies provided for in the

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Settlement Agreement. The parties therefore request that this Court retain jurisdiction to
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5 enforce the Settlement Agreement between the parties.
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DATED: January 7, 2020
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By:

/s/ James Kachmar
JAMES KACHMAR
WEINTRAUB TOBIN
Attorney for Defendant Doyle Rivers

By:

/s/ Carolyn Hoecker Luedtke
CAROLYN HOECKER LUEDTKE
MUNGER, TOLLES & OLSON LLP
Attorneys for Intel Corporation

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ECF ATTENTATION
I, Carolyn Hoecker Luedtke, am the ECF user whose account is being used to file this

14 document. In accordance with Civil Local Rule 5-1(i)(2), I attest that concurrence in the filing of
15 this document has been obtained from all signatories.
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-2STIPULATION OF DISMISSAL WITH PREJUDICE AND ORDER

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ORDER OF DISMISSAL

Pursuant to stipulation of the parties, the Court dismisses this action with prejudice.
Each party will bear its own attorneys’ fees and expenses. Pursuant to the settlement

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agreement, Defendant Doyle Rivers has provided a certification and the parties have
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6 agreed that if he violates the certification, they will file a stipulated joint motion with this
7 Court to enter an agreed upon permanent injunction. As such, this Court will retain
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jurisdiction to enforce the Settlement Agreement between the parties as well as impose the

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agreed upon remedies for any violations of the confidentiality certification provided for in
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11 the Settlement Agreement.
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IT IS SO ORDERED.

13 Dated: January 10, 2020
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-3STIPULATION OF DISMISSAL WITH PREJUDICE AND ORDER