AutoOpt Networks, Inc. v. Karani et al

Filing 101

ORDER Granting 100 Stipulation to Dismiss First Amended Complaint With Prejudice per FRCP RULE 23(e), 23.1(c), 23.2, and 66. Signed by Judge Haywood S. Gilliam, Jr. on 11/16/2018. (ndrS, COURT STAFF) (Filed on 11/16/2018)

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Paul J. Steiner (SBN 41117)
Law Offices of Paul J. Steiner
275 Battery Street, Suite 1300
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff and Counter-Defendant
AutoOpt Networks, Inc.

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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AUTOOPT NETWORKS, INC.,
a California corporation,
Plaintiff,
vs.
VIJAY KARANI, an individual; MOBILE
TERRANCE, INC., a California
corporation,
GNANENTHIRAN JAYANTHAN, an
individual,

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Defendants.
GNANENTHIRAN JAYANTHAN,
an individual,

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Counter-Claimant,

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vs.

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AUTOOPT NETWORKS, INC., a
California corporation
Counter-Defendant

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Case No.: 4:17-cv-04714-HSG

STIPULATION TO DISMISS FIRST
AMENDED COMPLAINT WITH
PREJUDICE PER FRCP RULE 23(e), 23.1(c),
23.2, and 66 and Order

Complaint Filed: 8/15/17
Counterclaim Filed: 9/25/17

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STIPULATION TO DISMISS FIRST AMENDED COMPLAINT WITH PREJUDICE
USDC-Northern
4:17-cv-04714-HSG

STIPULATION

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Pursuant to FRCP Rule 23(e), 23.1(c), 23.2 and 66, Plaintiff and Counter-Defendant
AUTOOPT NETWORKS, INC. and Defendant and Counter-Claimant, GNANENTHIRAN
JAYANTHAN, an individual, agree and stipulate that the First Amended Complaint herein only
may be and hereby is dismissed with prejudice.
Plaintiff and Counter-Defendant AUTOOPT NETWORKS, INC. and Defendant and
Counter-Complainant GNANENTHIRAN JAYANTHAN, an individual, further agree and
stipulate to the provisions and limitations as follows:
1. Each party will bear their own attorney’s fees in concerning the Plaintiff’s Complaint
and First Amended Complaint.
2. Defendant GNANENTHIRAN JAYANTHAN has not waived costs. Collection of
Defendant’s costs incurred in the defense of the First Amended Complaint shall be
deferred to be determined upon resolution of the Counter-Complaint either by
agreement, settlement or judgment and, if by judgment, thereafter by the filing of a
Memorandum of Costs.
3. The Counter-Complaint, and each and every claim therein, of GNANENTHIRAN
JAYANTHAN claiming work-related unpaid sums of money remains in full force
and effect.
4. The Parties to this Stipulation agree that dismissal of the First Amended Complaint
with prejudice does not limit either Party’s right to continue or seek any and all
depositions in the Counter-Complaint, which asserts no federal claims, which the
Parties expect will be remanded to state court once this Court dismisses the First
Amended Complaint.
Dated: November 15, 2018

Law Offices of Paul J. Steiner
/s/ Paul J. Steiner
By: ________________________
Paul J. Steiner
Attorneys for Plaintiff and Counter-Defendant
AUTOOPT NETWORKS, INC.

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Dated: November 15, 2018

Law Offices of Bob Camors

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/s/ Robert E. Camors, Jr.

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By: ________________________
Robert E. Camors,Jr.
Attorneys for Defendant and Counter-Claimant
GNANENTHIRAN JAYANTHAN

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ATTESTATION OF CONCURRENCE IN FILING

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of this document has been obtained from each of the other signatories, which shall serve in lieu
of their signatures on this document.
Dated: November 15, 2018

/s/ Paul J. Steiner
_________________________________
Paul J. Steiner
Attorney
ISTRIC for Plaintiff and CounterES D Defendant AUTOOPT NETWORKS, INC.
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Dated: 11/16/2018

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Pursuant to Local Rule 5-1(i)(3), the filer hereby attests that the concurrence in the filing

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STIPULATION TO DISMISS FIRST AMENDED COMPLAINT WITH PREJUDICE
USDC-Northern
4:17-cv-04714-HSG