Adobe Systems Incorporated v. Dracup et al

Filing 37

STIPULATION AND ORDER Dismissing Defendant Heather Dracup without prejudice. Signed by Judge Samuel Conti on 3/13/12. (tdm, COURT STAFF) (Filed on 3/13/2012)

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J. Andrew Coombs (SBN 123881)
[e-mail]
Annie S. Wang (SBN 243027)
[e-mail]
J. Andrew Coombs, A Prof. Corp.
517 East Wilson Avenue, Suite 202
Glendale, California 91206
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Plaintiff
Adobe Systems Incorporated
George A. Shohet (SBN 112697)
[e-mail]
Law Offices of George A. Shohet
245 Main Street, Suite 310
Venice, California 90291
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Defendant Heather Dracup

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO)

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Adobe Systems Incorporated,
Plaintiff,
v.
Jonathan Dracup, et al.,

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Defendants.

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Case No. CV11-3880 SC
JOINT STIPULATION TO DISIMISS
DEFENDANT HEATHER DRACUP
WITHOUT PREJUDICE PURSUANT
TO FED. R. CIV. P. 41(a)(1)(A)

Pursuant to Fed. R. Civ. P. 41(a)(1)(A), Plaintiff Adobe Systems Incorporated (“Adobe”)
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and Defendant Heather Dracup by and through their respective counsels of record, hereby stipulate
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and agree as follows:
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WHEREAS Plaintiff filed its complaint against Defendant Heather Dracup on or about
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August 8, 2011;
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WHEREAS Defendant Heather Dracup has not served an answer or motion for summary
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judgment;
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Adobe v. Dracup, et al.: Stip. to Dismiss without Prejudice re
Heather Dracup, Only

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WHEREAS based upon Defendant Heather Dracup’s representations, Plaintiff has agreed

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to dismiss, without prejudice, Defendant Heather Dracup from this action;
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WHEREAS Defendant Heather Dracup agrees that any and all applicable statutes of
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limitations are tolled effective August 8, 2011, through and until the earlier of the final disposition
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or end of the discovery period of the above-captioned action ;
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NOW, THEREFORE, the Parties stipulate and agree that based upon the above agreements,
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Defendant Heather Dracup, only, shall be dismissed without prejudice, each party to bear its own
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costs and fees.
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IT IS SO STIPULATED.
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DATED: March 6, 2012

J. Andrew Coombs, A Professional Corp.

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By: __/s/ Annie S. Wang_____________________
J. Andrew Coombs
Annie S. Wang
Attorneys for Plaintiff Adobe Systems Incorporated

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DATED: March 6, 2012

Law Offices of George A. Shohet

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By: __/s/ George A. Shohet___________________
George A. Shohet
Attorney for Defendant Heather Dracup

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS HEREBY ORDERED that Defendant Heather

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Dracup, only, shall be dismissed without prejudice, any and all applicable statutes of limitations are

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tolled effective August 8, 2011, through and until the earlier of the final disposition or end of the

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discovery period of the above-captioned action, and each party to bear its own costs and fees.

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DATED:

3/13/12

UNIT
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S DISTRICT
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Heather Dracup, Only

Judge S

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Adobe v. Dracup, et al.: Stip. to Dismiss without Prejudice re

onti

amuel C

NO

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FO

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R NIA

Hon. Samuel Conti
ERED
United States DistrictO ORD
IT IS S Judge

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