CSAA Ins. Exchange v. Dynamic Solutions Worldwide, LLC et al

Filing 19

STIPULATION and ORDER signed by District Judge Daniel J. Calabretta on 05/10/2024 DISMISSING 1 Notice of Removal with prejudice pursuant to the terms set forth herein. (Nair, C)

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SPINELLI, DONALD & NOTT
A Professional Corporation
ROSS R. NOTT, (State Bar No. 172235)
300 University Avenue, Suite 100
Sacramento, CA 95825
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant and Cross-Defendant
WOODSTREAM CORPORATION

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION

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vs.

Plaintiffs,

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DYNAMIC SOLUTIONS WORLDWIDE,
LLC, WOODSTREAM CORPORATION,
COSTCO WHOLESALE CORPORATON
and DOES 1 to 20,

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Defendants.

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Case No.: 2:23-cv-01156-DJC-DMC

CSAA INSURANCE EXCHANGE,

STIPULATION OF DISMISSAL
WITH PREJUDICE AND ORDER
Complaint Filed Butte County Superior
Court: May 15, 2023

COSTCO WHOLESALE CORPORATION,
vs.

Cross-Claimant,

DYNAMIC SOLUTIONS WORLDWIDE,
LLC, WOODSTREAM CORPORATION,
and ROES 1-23, inclusive,
Cross-Defendants.

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SPINELLI, DONALD &
NOTT

Pursuant to Rule 41(a)(1) of the Federal Rules of Civil Procedure, and for good
cause stated herein, the parties stipulate that the Complaint of CSAA Insurance Exchange brought
as to Defendants identified as Dynamic Solutions Worldwide, LLC, Woodstream Corporation, and
Costco Wholesale Corporation shall be dismissed by the Court, with prejudice. As between
Plaintiff and Defendants, they shall bear their own costs and fees associated with this matter
including attorney’s fees.
Stipulation of Dismissal with Prejudice and Order

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As to the cross-claim of Costco Wholesale Corporation against Dynamic Solutions,

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Worldwide, LLC, and Woodstream Corporation, that action shall be subject to a separate dismissal

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as those parties are resolving defense and indemnity obligations between themselves.

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IT IS SO STIPULATED.

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DATED: __5/9/24_______________

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____/s/Robert E. Wall________________________
Robert E. Wall

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Attorneys for Plaintiff,
CSAA INSURANCE EXCHANGE

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THE GRUNSKY LAW FIRM

DATED: __5/8/24__________

MAIRE & DEEDON

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___/s/Patrick L. Deedon______________________
Patrick L. Deedon

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Attorneys for Defendant/Cross-Claimant,
COSTCO WHOLESALE CORPORATION

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DATED: _5/9/24__________

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_/s/Ross R. Nott____________________________
Ross R. Nott

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Attorneys for Defendant,
WOODSTREAM CORPORATION

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SPINELLI, DONALD & NOTT

ORDER
It is hereby ordered that Plaintiff CSAA Insurance Exchange’s Complaint as to Dynamic
Solutions Worldwide, LLC, Woodstream Corporation, and Costco Wholesale Corporation as well
as all Does identified therein shall be and are dismissed with prejudice pursuant to the terms set
forth herein.
IT IS SO ORDERED.
Dated: May 10, 2024

/s/ Daniel J. Calabretta
THE HONORABLE DANIEL J. CALABRETTA
UNITED STATES DISTRICT JUDGE

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SPINELLI, DONALD &
NOTT

Stipulation of Dismissal with Prejudice and Order

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