Lloyd v. Blokihn et al

Filing 23

STIPULATION FOR DISMISSAL AND ORDER re 22 Stipulation filed by Kurt D Lloyd. Signed by Judge Paul S. Grewal on 11/13/2012. (ofr, COURT STAFF) (Filed on 11/13/2012) (Additional attachment(s) added on 11/14/2012: # 1 CERTIFICATE OF SERVICE) (ofr, COURT STAFF).

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Jeffrey E. Essner, Bar No. 121438
[e-mail]
Erik P. Khoobyarian, Bar No. 226749
[e-mail]
HOPKINS & CARLEY
A Law Corporation
The Letitia Building
70 S First Street
San Jose, CA 95113-2406
mailing address:
P.O. Box 1469
San Jose, CA 95109-1469
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiff
KURT D. LLOYD

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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KURT D. LLOYD,

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Plaintiff,

CASE NO. CV11-06219 PSG
STIPULATION FOR DISMISSAL
AND ORDER

v.
NICHOLAI BLOKHIN, AVIMOS USA
LLC, VAL BOTCHAROV, and DOES 1 50, inclusive,

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Defendants.

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IT IS HEREBY STIPULATED by and between the plaintiff KURT D. LLOYD

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(“Plaintiff”) and the Defendants AVIMOS USA LLC and VAL BOTCHAROV that the entire

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above-captioned action are hereby dismissed with prejudice as to Defendants AVIMOS USA

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LLC and VAL BOTCHAROV pursuant to Fed. R. Civ. Proc. 41(a)(1); each party to bear its own

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costs. Defendant NICHOLAI BLOKHIN has not been served or appeared in the instant action

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and Plaintiff requests that Defendant NICHOLAI BLOKHIN be dismissed without prejudice.

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Plaintiff and Defendants AVIMOS USA LLC and VAL BOTCHAROV request that the Court

H OPKINS & C ARLEY
ATTORNEYS AT LAW
SAN JOSE

642\929361.1
STIPULATION FOR DISMISSAL

CASE NO. CV11-06219 PSG

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retain jurisdiction should intervention be required regarding performance under the settlement

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agreement entered into between them.

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Dated: October 18, 2012

HOPKINS & CARLEY
A Law Corporation

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By: /S/ Erik P. Khoobyarian
Erik P. Khoobyarian
Attorneys for Plaintiff
KURT D. LLOYD

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Dated: October 18, 2012

VALLA & ASSOCIATES, INC.

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By: /S/ Michael Purcell
Michael Purcell
Attorneys for Defendants AVIMOS USA LLC
and VAL BOTCHAROV

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ATTESTATION OF ERIK P. KHOOBYARIAN

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I, Erik P. Khoobyarian, am one of the attorneys of record for Plaintiff KURT D. LLOYD.

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I have obtained concurrence in the filing of this document from Michael Purcell attorney of

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record for Defendants AVIMOS USA LLC and VAL BOTCHAROV, which shall serve in lieu

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of his signature on the filed document. I have obtained and will maintain records to support this

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concurrence for subsequent production for the court if so ordered or for inspection upon request

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by a party until one year after final resolution of the action (including appeal, if any).

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Dated: October 18, 2012

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By: /S/ Erik P. Khoobyarian
Erik P. Khoobyarian

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IT IS SO ORDERED.
Date: November 13, 2012

__________________________
Honorable Paul S. Grewal
U.S. Magistrate Judge

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H OPKINS & C ARLEY
ATTORNEYS AT LAW
SAN JOSE

642\929361.1
STIPULATION FOR DISMISSAL

-2CASE NO. CV11-06219 PSG