Rand v. Citibank, N.A.

Filing 30

STIPULATION AND ORDER OF DISMISSAL WITH PREJUDICE 29 . Signed by Judge Nathanael Cousins on 5/11/2015. (lmh, COURT STAFF) (Filed on 5/11/2015)

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JONATHAN D. WOLF, CA STATE BAR NO. 127043
SARA L. POLLOCK, CA STATE BAR NO. 281076
BERLINER COHEN
TEN ALMADEN BOULEVARD
ELEVENTH FLOOR
SAN JOSE, CALIFORNIA 95113-2233
TELEPHONE: [phone]
FACSIMILE: [phone]
[e-mail]
[e-mail]

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ATTORNEYS FOR PLAINTIFF DAVID L. RAND
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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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DAVID L. RAND,
Plaintiff,

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CASE NO. 5:14-CV-04772-NC
STIPULATION OF DISMISSAL WITH
PREJUDICE

v.
CITIBANK, N.A.,

[PROPOSED] ORDER OF DISMISSAL
WITH PREJUDICE

Defendant.

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4852-7113-4755v1
SPOLLOCK\10876002

CASE NO. 5:14-CV-04772-NC

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STIPULATION OF DISMISSAL WITH PREJUDICE AND [PROPOSED] ORDER FOR DISMISSAL WITH PREJUDICE

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STIPULATION OF DISMISSAL WITH PREJUDICE

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Pursuant to Fed. R. Civ. P. 41(a)(1)(A), and subject to the approval of the Court, IT IS

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HEREBY STIPULATED AND AGREED by and between Plaintiff David L. Rand (“Rand”) and

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Defendant Citibank N.A. (“Citibank”) that Case No. 5:14-CV-04772-NC be dismissed with

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prejudice, with each party to bear its own costs, expenses, and attorneys' fees.

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Respectfully Submitted,
DATED: MAY 11, 2015

BERLINER COHEN LLP

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BY: /S/ JONATHAN D. WOLF
JONATHAN D. WOLF
SARA L. POLLOCK
ATTORNEYS FOR PLAINTIFF DAVID L. RAND

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DATED: MAY 11, 2015

DOLL AMIR & ELEY LLP

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BY: /S/ HUNTER R. ELEY
HUNTER R. ELEY
ATTORNEYS FOR DEFENDANT CITIBANK N.A.

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[PROPOSED] ORDER OF DISMISSAL WITH PREJUDICE

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PURSUANT TO STIPULATION, IT IS HEREBY ORDERED that Case No. 5:14-CV-

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04772-NC is dismissed with prejudice, with each party to bear its own costs, expenses, and

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attorneys' fees.

SO ORDERED.

DATED: May 11, 2015

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4852-7113-4755v1
SPOLLOCK\10876002

ousins

CASE NO. 5:14-CV-04772-NC

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HONORABLE NATHANEALeCOUSINS
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JudgNITED STATES DISTRICT COURT
JUDGE OF THE U

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BY:

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STIPULATION OF DISMISSAL WITH PREJUDICE AND [PROPOSED] ORDER FOR DISMISSAL WITH PREJUDICE

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SIGNATURE ATTESTATION

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I, Jonathan D. Wolf, am the ECF user whose identification and password are being used to

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file this STIPULATION OF DISMISSAL WITH PREJUDICE; [PROPOSED] ORDER OF

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DISMISSAL WITH PREJUDICE in compliance with Civil L.R. 6-2 and 7-12. Concurrence to the

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filing of this document was obtained from Hunter R. Eley, counsel for Citibank N.A., on May 11,

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2015. I declare under penalty of perjury under the laws of the United States that the foregoing is true

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and correct.

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DATED: MAY 11, 2015

BERLINER COHEN

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BY: /S/ JONATHAN D. WOLF
JONATHAN D. WOLF
SARA L. POLLOCK
ATTORNEYS FOR PLAINTIFF DAVID L. RAND

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4852-7113-4755v1
SPOLLOCK\10876002

CASE NO. 5:14-CV-04772-NC

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STIPULATION OF DISMISSAL WITH PREJUDICE AND [PROPOSED] ORDER FOR DISMISSAL WITH PREJUDICE