Hughes v. Experian Information Solutions, Inc. et al

Filing 54

STIPULATION AND ORDER re (51 in 3:16-cv-06329-JST) STIPULATION WITH PROPOSED ORDER (for dismissal of Defendant JPMorgan Chase Bank, N.A.) filed by Rhodora Cristobal. Signed by Judge Jon S. Tigar on October 10, 2017. (wsn, COURT STAFF) (Filed on 10/10/2017)

Scott Sagaria (State Bar No.217981)
1 [e-mail]
Elliot Gale (State Bar No. 263326)
2 [e-mail]
Joe Angelo (State Bar No. 268542)
3 [e-mail]
SAGARIA LAW, P.C.
4 3017 Douglas Blvd., Ste. 100
Roseville, California 95661
5 Telephone: [phone]
Facsimile: [phone]
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Attorneys for Plaintiff
7 Rhodora Cristobal
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA — SAN FRANCISCO DIVISION

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12 RHODORA CRISTOBAL,
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Federal Case No.: 3:16-cv-06329-JST

Plaintiff,

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vs.

15 EQUIFAX, INC.; et. al.,
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STIPULATION OF DISMISSAL WITH
PREJUDICE OF DEFENDANT
JPMORGAN CHASE BANK, N.A.;
[PROPOSED] ORDER

Defendants.

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IT IS HEREBY STIPULATED by and between plaintiff Rhodora Cristobal and
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defendant Chase Bank USA, N.A. (erroneously sued as JPMorgan Chase Bank, N.A., and
referred to herein as “Chase”), through their designated counsel, that Chase be dismissed with
prejudice from the above-captioned action pursuant to Federal Rules of Civil Procedure, Rule

22 41(a)(2). As a condition of entering into this stipulation, Chase is reserving its rights to file,
23 within 30 days from the date of this stipulation, a motion to recover its attorneys’ fees and costs
24 incurred in connection with its defense of this action.
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STIPULATION OF DISMISSAL OF DEFENDANT JPMORGAN CHASE BANK, N.A.; [PROPOSED] ORDER

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DATED: October 9, 2017

Sagaria Law, P.C.

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By:

/s/ Elliot W. Gale
Elliot W. Gale
Attorneys for Plaintiff
Rhodora Cristobal

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8 DATED: October 9, 2017

Covington and Burling LLP

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By:

/s/Megan Rodgers
Megan Rodgers
Attorneys for Defendant
Chase Bank USA, N.A. (erroneously sued as JPMorgan
Chase Bank, N.A.)

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15 I, Elliot Gale, am the ECF user whose identification and password are being used to file this
16 Stipulation. I hereby attest that Megan Rodgers has concurred in this filing.
/s/ Elliot Gale
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[PROPOSED] ORDER

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Pursuant to the stipulation of the Parties, Chase is dismissed with prejudice from the
above-captioned action.
IT IS SO ORDERED.
DATED: October 10, 2017
JON S. TIGAR
UNITED STATES DISTRICT JUDGE

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STIPULATION OF DISMISSAL OF DEFENDANT JPMORGAN CHASE BANK, N.A.; [PROPOSED] ORDER