Redd, et al v. Daley, et al

Filing 247

STIPULATION AND ORDER re 246 STIPULATION WITH PROPOSED ORDER DISMISSAL WITHOUT PREJUDICE filed by MIchael D. Daley. Signed by Judge Edward M. Chen on 3/2/15. (bpf, COURT STAFF) (Filed on 3/2/2015)

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RISHI N. SHARMA (Cal. State Bar No. 239034)
PETER A. COOPER (Cal. State Bar No. 275300)
PAUL HASTINGS LLP
55 Second Street, 24th Floor
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff
Paul A. Redd, Jr.
KAMALA D. HARRIS
Attorney General of California
DANIELLE F. O'BANNON
Supervising Deputy Attorney General
TRACE O. MAIORINO
Deputy Attorney General
SHARON A. GARSKE
Deputy Attorney General
State Bar No. 215167
455 Golden Gate Avenue, Suite 11000
San Francisco, CA 94102-7004
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendant
Michael D. Daley

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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PAUL A. REDD, JR.,

C-98-20429 EMC
Plaintiff, STIPULATION OF VOLUNTARY
DISMISSAL WITHOUT PREJUDICE;
PROPOSED ORDER

v.
STEVEN CAMBRA, JR., et al.,

Judge:
Defendants. Trial Date:

Honorable Edward M. Chen
June 15, 2015

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Stip. Voluntary Dismissal Without Prejudice; Proposed Order (C-98-20429 EMC)

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Plaintiff Paul A. Redd and Defendant Michael D. Daley have resolved this case in its
entirety. Each party shall bear its own litigation costs and attorney’s fees.
The parties jointly request that the Court vacate all deadlines and the June 15, 2015 trial

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date. The parties will file a dismissal with prejudice upon finalizing the settlement agreement and

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release and payment of the settlement monies.

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The parties stipulate to a dismissal of this action without prejudice under Federal Rule of

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Civil Procedure 41(a)(1)(A)(ii).

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IT IS SO STIPULATED.

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Dated: February 26, 2015

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PAUL HASTINGS LLP
By:

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/s/RISHI N. SHARMA
RISHI N. SHARMA
PETER A. COOPER
Attorneys for Plaintiff Paul A. Redd

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Dated: February 26, 2015

KAMALA D. HARRIS
Attorney General of The State of California

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By:

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ORDER

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IT IS SO ORDERED.
Dated:

3/2/15

S DISTRICT
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C
TA

DERED

O OR
IT IS S

The Honorable Edward M. Chen

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ard M.

NO

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dw
Judge E

Chen

R NIA

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monies. The Clerk shall close the file.

RT
U
O

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prejudice upon finalizing the settlement agreement and release and payment of the settlement

FO

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deadlines, including the June 15, 2015 trial date are vacated. The parties will file a dismissal with

S

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In accordance with the parties stipulation, this action is dismissed without prejudice. All

UNIT
ED

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/s/SHARON A. GARSKE
TRACE O. MAIORINO
SHARON A. GARSKE
Deputy Attorney General
Attorneys for Defendant Michael D. Daley

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H

ER

LI

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Stip. Voluntary Dismissal Without Prejudice; Proposed Order (C-98-20429 EMC)

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C

CERTIFICATE OF SERVICE
Case Name:

Redd v. Cambra, et al.

No.

C-98-20429 EMC

I hereby certify that on February 27, 2015, I electronically filed the following documents with
the Clerk of the Court by using the CM/ECF system:
STIPULATION OF VOLUNTARY DISMISSAL WITHOUT PREJUDICE; PROPOSED
ORDER
I certify that all participants in the case are registered CM/ECF users and that service will be
accomplished by the CM/ECF system.
I declare under penalty of perjury under the laws of the State of California the foregoing is true
and correct and that this declaration was executed on February 27, 2015, at San Francisco,
California.

D. Criswell
Declarant
41223611.doc

s/ D. Criswell
Signature