Gail Morales v. Cal eConnect, Inc. et al
Filing
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ORDER re 14 Stipulation for Dismissal without prejudice filed by Gail Morales. David Lansky, Donald Crane and David Joyner terminated. Signed by Judge Charles R. Breyer on 10/6/2015. (beS, COURT STAFF) (Filed on 10/7/2015)
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Russell A. Robinson, SBN 163937
Law Office of Russell A. Robinson
345 Grove Street, 1st Floor
San Francisco, CA 94102
Phone:
415.255.0462
Fax:
415.431.4526
rlaw345@gmail.com
Counsel for Plaintiff
GAIL MORALES
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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GAIL MORALES,
Case No.
15-CV-4383-CRB
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Plaintiff,
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v.
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STIPULATION FOR DISMISSAL OF CERTAIN
INDIVIDUAL DEFENDANTS DONALD CRANE,
DAVID LANSKY, AND DAVID JOYNER,
WITHOUT PREJUDICE
CAL ECONNECT, INC., et al.,
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ORDER
Defendants.
___________________________________/ [Jury Trial Demanded]
THE PARTIES HERETO, THROUGH COUNSEL OF RECORD, HEREBY AGREE AND
STIPULATE AS FOLLOWS:
This is an employment-related case filed in State Court by Plaintiff Gail Morales on
September 2, 2014.
All named Defendants joined in and consented to removal of the action pursuant to 28
USC section 1446(b)(2), and this action was removed to federal court on September 24, 2015.
The parties hereto, through counsel of record, hereby stipulate pursuant to Federal
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Rules of Civil Procedure, Rule 41(a), that the following named defendants shall be dismissed
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without prejudice: Donald Crane, David Lansky, and David Joyner.
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Each party to this stipulation agrees that in exchange for dismissal, each shall bear
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his/her own costs of suit and attorneys’ fees expended as to the dismissed defendants, only;
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and, that each of the dismissed defendants will appear at deposition pursuant to reasonable
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notice and without the need to subpoena or to pay a witness fee, on dates, and at times and
____________________________________________________________________________________
Morales v. Cal econnect, Inc., et al.
P012STIP
STIPULATION FOR DISMISSAL; ORDER
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places mutually agreed upon. The location of these depositions will be pursuant to Federal
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Rules of Civil Procedure, Rule 45.
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After dismissal of these three defendants, the named parties remaining are Plaintiff Gail
Morales and Defendants Cal eConnect, Inc., and Laura Landry.
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Date: September __, 2015
/s/ Russell A. Robinson
By:
Russell A. Robinson
Law Office of Russell A. Robinson
Counsel for Plaintiff
GAIL MORALES
Date: September __, 2015
/s/
By:
Lauren M. Cooper, Esq.
Villarreal Hutner PC
Counsel for Defendants
CAL eCONNECT, INC., LAURA LANDRY,
DONALD CRANE, DAVID LANSKY, and
DAVID JOYNER
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///
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____________________________________________________________________________________
Morales v. Cal econnect, Inc., et al.
P012STIP
-2STIPULATION FOR DISMISSAL; ORDER
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ORDER
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Good cause appearing, the Court hereby orders as follows:
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The parties’ stipulation is hereby adopted as the Order of this Court. Pursuant to
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Federal Rules of Civil Procedure, Rule 41(a), Defendants Donald Crane, David Lansky, and
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David Joyner shall be and are hereby dismissed from this action, without prejudice: .
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Each party to this stipulation shall bear his/her own costs of suit and attorneys’ fees
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expended as to the dismissed defendants, only; and, each of the dismissed defendants will
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appear at deposition pursuant to reasonable notice to defense counsel and without the need to
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subpoena or to pay a witness fee, on dates, and at times and places mutually agreed upon.
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The location of these depositions will be pursuant to Federal Rules of Civil Procedure, Rule 45.
IT IS SO ORDERED.
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Date: October 6, 2015
Honorable CHARLES R. BREYER
Judge, United States District Court
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____________________________________________________________________________________
Morales v. Cal econnect, Inc., et al.
P012STIP
-3STIPULATION FOR DISMISSAL; ORDER
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