Gail Morales v. Cal eConnect, Inc. et al

Filing 17

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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1 2 3 4 5 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 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 GAIL MORALES, Case No. 15-CV-4383-CRB 11 Plaintiff, 12 v. 13 STIPULATION FOR DISMISSAL OF CERTAIN INDIVIDUAL DEFENDANTS DONALD CRANE, DAVID LANSKY, AND DAVID JOYNER, WITHOUT PREJUDICE CAL ECONNECT, INC., et al., 14 15 16 17 18 19 20 21 22 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 23 Rules of Civil Procedure, Rule 41(a), that the following named defendants shall be dismissed 24 without prejudice: Donald Crane, David Lansky, and David Joyner. 25 Each party to this stipulation agrees that in exchange for dismissal, each shall bear 26 his/her own costs of suit and attorneys’ fees expended as to the dismissed defendants, only; 27 and, that each of the dismissed defendants will appear at deposition pursuant to reasonable 28 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 1 places mutually agreed upon. The location of these depositions will be pursuant to Federal 2 Rules of Civil Procedure, Rule 45. 3 4 After dismissal of these three defendants, the named parties remaining are Plaintiff Gail Morales and Defendants Cal eConnect, Inc., and Laura Landry. 5 6 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 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 /// 28 ____________________________________________________________________________________ Morales v. Cal econnect, Inc., et al. P012STIP -2STIPULATION FOR DISMISSAL; ORDER 1 ORDER 2 Good cause appearing, the Court hereby orders as follows: 3 The parties’ stipulation is hereby adopted as the Order of this Court. Pursuant to 4 Federal Rules of Civil Procedure, Rule 41(a), Defendants Donald Crane, David Lansky, and 5 David Joyner shall be and are hereby dismissed from this action, without prejudice: . 6 Each party to this stipulation shall bear his/her own costs of suit and attorneys’ fees 7 expended as to the dismissed defendants, only; and, each of the dismissed defendants will 8 appear at deposition pursuant to reasonable notice to defense counsel and without the need to 9 subpoena or to pay a witness fee, on dates, and at times and places mutually agreed upon. 10 11 The location of these depositions will be pursuant to Federal Rules of Civil Procedure, Rule 45. IT IS SO ORDERED. 12 13 14 15 Date: October 6, 2015 Honorable CHARLES R. BREYER Judge, United States District Court 16 17 18 19 20 21 22 23 24 25 26 27 28 ____________________________________________________________________________________ Morales v. Cal econnect, Inc., et al. P012STIP -3STIPULATION FOR DISMISSAL; ORDER

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