Wilbur-Ellis Company v. Ag Leader Technology, Inc.

Filing 30


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1 2 3 4 5 6 7 8 Roy S. Gordet SBN 103916 Law Office of Roy S. Gordet 235 Westlake Center #452 Daly City, CA 94015 Tel. 650-757-6147 Email roy@copyrightdirection.com Randy Troxel SBN 177105 Trademark-Associates 900 Cherry Avenue, Suite 300 San Bruno, CA 94066 Tel. 650-692-1700 Fax 650-794-2601 Email rtroxel@tmassoc.com 9 Attorneys for Plaintiff Wilbur- Ellis Company 10 11 UNITED STATES DISTRICT COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 14 Wilbur-Ellis Company, a California corporation; 15 Plaintiff, 16 Case No: CV 12 1270 LB vs. 17 18 19 Voluntary Dismissal Without Prejudice and Stipulation Concerning the Court’s Retaining Jurisdiction, and [Proposed] Order Thereon Ag Leader Technology, Inc., an Iowa corporation; Federal Rule 41(a) Defendant 20 Pursuant to a comprehensive settlement agreement entered into between the parties, 21 Plaintiff Wilbur-Ellis Company, by its undersigned counsel of record, hereby dismisses 22 WITHOUT prejudice this entire action against Defendant Ag Leader Technology, Inc. Each 23 party will bear its own costs and attorneys fees. 24 Defendant Ag Leader Technology, Inc., by its undersigned counsel of record, hereby 25 expressly consents that this dismissal is WITHOUT prejudice. 26 27 28 1 Voluntary Dismissal Without Prejudice Case No. CV 12 1270 LB 1 Further pursuant to the aforementioned settlement agreement entered into between the 2 parties, the parties by their undersigned counsel below jointly stipulate that Magistrate Judge 3 Laurel Beeler shall retain jurisdiction over the Parties and the subject matter to enforce the terms 4 of the aforementioned settlement agreement. 5 6 Respectfully submitted, Date: November 19, 2012 7 ____________/s/_______________ Roy S. Gordet, Counsel of Record for Plaintiff Wilbur-Ellis Company 8 9 10 11 12 Defendant Ag Leader Technology, Inc. consents to the dismissal without prejudice and stipulates to the Court’s retention of jurisdiction as set forth herein. Date: November 19, 2012 13 /s/_Stanley J. Thompson____________ Stanley J. Thompson, Counsel of Record for Defendant Ag Leader Technology Inc. 14 15 ORDER 16 Good cause appearing, this entire action is dismissed WITHOUT prejudice and the Court 17 shall retain jurisdiction over the parties in the event that it is necessary for either party to seek the 18 Court’s assistance in enforcing the terms of the settlement agreement entered into by the parties. 19 20 IT IS SO ORDERED. 21 Date: November 26, 2012 22 ________________________________________ Magistrate Judge Laurel Beeler 23 24 25 26 27 28 2 Voluntary Dismissal Without Prejudice Case No. CV 12 1270 LB

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