Frazier v. U.S. Bank National Association et al

Filing 20

JOINT STIPULATION OF DISMISSAL AND ORDER OF DISMISSAL WITHOUT PREJUDICE by Judge Jon S. Tigar granting 19 Stipulation. Civil case terminated. (kc, COURT STAFF) (Filed on 6/5/2024)

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1 2 3 4 5 6 7 8 9 10 Joan B. Tucker Fife (SBN 144572) JFife@winston.com WINSTON & STRAWN LLP 101 California Street San Francisco, CA 94111-5840 Telephone: (415) 591-1000 Facsimile: (415) 591-1400 Emilie C. Woodhead (SBN 240464) ewoodhead@winston.com Winston K. Hu (SBN 306677) WHu@winston.com WINSTON & STRAWN LLP 333 S. Grand Ave. Los Angeles, CA 90071-1543 Telephone: +1 213-615-1700 Facsimile: +1 213-615-1750 11 Attorneys for Defendant U.S. BANK NATIONAL ASSOCIATION 12 Additional Counsel – Next Page 13 14 UNITED STATES DISTRICT COURT 15 NORTHERN DISTRICT OF CALIFORNIA 16 17 KALIEN FRAZIER, on behalf of himself and others similarly situated, Plaintiff, 18 19 20 21 22 vs. U.S. BANK NATIONAL ASSOCIATION, and DOES 1 to 100, inclusive, Case No. 4:23-cv-05675 JOINT STIPULATION OF DISMISSAL AND [PROPOSED] ORDER OF DISMISSAL WITHOUT PREJUDICE Judge: Hon. Jon S. Tigar Defendant. 23 24 25 26 27 28 JOINT STIPULATION OF DISMISSAL AND [PROPOSED] ORDER OF DISMISSAL WITHOUT PREJUDICE 1 CASE NO. 4:23-cv-05675 1 2 3 4 5 6 7 8 9 Joseph Lavi jlavi@lelawfirm.com Vincent C. Granberry vgranberry@lelawfirm.com Cassandra Castro ccastro@lelawfirm.com LAVI & EBRAHIMIAN, LLP 8889 W. Olympic Blvd, Suite 200 Beverly Hills, CA 90211 Telephone: Facsimile: Email: (310) 432-0000 (310) 432-0001 Attorneys for Plaintiff KALIEN FRAZIER 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JOINT STIPULATION OF DISMISSAL AND [PROPOSED] ORDER OF DISMISSAL WITHOUT PREJUDICE 2 CASE NO. 4:23-cv-05675 1 2 STIPULATION TO DIMISS Plaintiff KALIEN FRAZIER (“Plaintiff”) and Defendant U.S. BANK NATIONAL 3 ASSOCIATION (“Defendant”) (collectively, the “Parties”), by and through their respective, 4 undersigned counsel, hereby jointly stipulate and agree that Kalien Frazier hereby dismisses without 5 prejudice the entire action and all claims being asserted against Defendant in the above-captioned action 6 pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure. Each side shall bear its own 7 costs and attorneys’ fees. 8 9 10 WHEREFORE, the Parties hereby request that the Court dismiss this case without prejudice, with each Party to bear his or its own costs and attorneys’ fees. IT IS SO STIPULATED. 11 12 Dated: June 4, 2024 13 LAVI & EBRAHIMIAN, LLP By:/s/ Cassandra Castro Joseph Lavi Vincent C. Granberry Cassandra Castro Attorneys for Plaintiff KALIEN FRAZIER 14 15 16 17 18 19 20 21 22 Dated: June 4, 2024 WINSTON & STRAWN LLP By:/s/ Emilie C. Woodhead Joan B. Tucker Fife Emilie C. Woodhead Winston K. Hu Attorneys for Defendant U.S. BANK NATIONAL ASSOCIATION 23 24 25 26 27 28 JOINT STIPULATION OF DISMISSAL AND [PROPOSED] ORDER OF DISMISSAL WITHOUT PREJUDICE 3 CASE NO. 4:23-cv-05675 1 2 3 ATTESTATION PURSUANT TO LOCAL RULE 5-1 (i)(3) Pursuant to Local Rule 5-1 (i)(3), regarding signatures, I attest under penalty of perjury that the concurrence in the filing of this document has been obtained from its signatories. 4 5 Dated: June 4, 2024 /s/Emilie C. Woodhead Emilie C. Woodhead 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JOINT STIPULATION OF DISMISSAL AND [PROPOSED] ORDER OF DISMISSAL WITHOUT PREJUDICE 1 CASE NO. 4:23-cv-05675 1 [PROPOSED] ORDER OF DISMISSAL 2 Pursuant to the Stipulation of all Parties who have appeared in the action and good cause 3 appearing, the Court ORDERS the following: Pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure, this action and all 4 5 claims asserted in the above-captioned action by Plaintiff against the Defendant are DISMISSED 6 WITHOUT PREJDUCE. Each party shall bear its own costs and attorneys’ fees. The Clerk of the Court 7 is directed to close the case. 8 9 IT IS SO ORDERED. 10 11 Dated: June 5, 2024 12 13 14 Honorable Jon S. Tigar United States District Court Judge 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JOINT STIPULATION OF DISMISSAL AND [PROPOSED] ORDER OF DISMISSAL WITHOUT PREJUDICE 1 CASE NO. 4:23-cv-05675

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