Aguila-Reynoso v. Blossom Valley Construction, Inc.

Filing 18

ORDER DISMISSING CASE WITH PREJUDICE. Signed by Magistrate Judge Howard R. Lloyd on 11/17/2016. (hrllc2, COURT STAFF) (Filed on 11/17/2016)

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5 TOMAS E. MARGAIN, Bar No. 193555 HUY TRAN, Bar No. 288196 Justice at Work Law Group 84 West Santa Clara Street, Suite 790 San Jose, CA 95113 Telephone: (408) 317-1100 Facsimile: (408) 351-0105 Tomas@JAWLawGroup.com Huy@JAWLawGroup.com 6 Attorneys for Plaintiffs SERGIO AGUILA-REYNOSO 1 2 3 4 7 UNITED STATES DISTRICT COURT 8 NORTHERN DISTRICT OF CALIFORNIA 9 SAN JOSE DIVISION 10 11 SERGIO AGUILA-REYNOSO, 12 Plaintiff, 13 v. 14 15 16 Case No. 16-cv-3372-HRL BLOSSOM VALLEY CONSTRUCTION, INC., NOTICE OF DISMISSAL WITH PREJUDICE; REQUEST THAT MATTER BE DISMISSED AND THAT CLERK CLOSE FILE; [PROPOSED] ORDER Defendant Re: Dkt. 17 17 18 19 20 TO THE COURT AND ALL PARTIES TO THIS ACTION: NOTICE IS HEREBY given that Plaintiff SERGIO AGUILA-REYNOSO hereby requests 21 that Defendant BLOSSOM VALLEY CONSTRUCTION, INC be Dismissed with prejudice. This 22 notice is accompanied by the declaration of counsel and proposed order. 23 24 25 26 27 28 1 NOTICE OF DISMISSAL 1 Dated: November 17, 2016 2 //s//Tomas E. Margain//s// Tomas E. Margain Huy Tran JUSTICE AT WORK LAW GROUP Attorneys for Plaintiff SERGIO AGUILA-REYNOSO 3 4 5 6 7 DECLARATION OF TOMAS E. MARGAIN 8 9 10 11 12 13 14 15 16 17 18 19 I, Tomas E. Margain, declare as follows: 1. I am the attorney of record for Plaintiff SERGIO AGUILA-REYNOSO in this case. I have personal knowledge of the facts set forth in this declaration, and, if called as a witness, I could and would testify thereto. 2. After being sued, Defendants hired Frank J. Perretta of Miller, Morton, Caillat & Nevis, LLP. I was able to settle my client’s dispute over the course of several negotiations conferences with Mr. Perretta. 3. The matter was settled prior to Defendants entering an appearance and as such I cannot submit a stipulation and order to Dismiss with prejudice. 4. I have the authority of my client to have this case Dismissed with Prejudice. 20 21 I declare under penalty of perjury pursuant to the laws of the United States that the foregoing is true and correct, executed on November 17, 2016 in San Jose, California. 22 //s// Tomas Margain Tomas E. Margain 23 24 25 26 27 28 2 NOTICE OF DISMISSAL 1 UNITED STATES DISTRICT COURT 2 NORTHERN DISTRICT OF CALIFORNIA 3 SAN JOSE DIVISION 4 5 SERGIO AGUILA-REYNOSO, 6 Plaintiff, 7 v. 8 9 10 13 14 15 16 ORDER DISMISSING CASE WITH PREJUDICE BLOSSOM VALLEY CONSTRUCTION, INC., Defendant 11 12 Case No. 16-cv-3372-HRL ORDER Based on GOOD CAUSE shown and upon the Notice and Declaration of Plaintiff’s counsel Tomas E. Margain, the Court orders as follows: The matter is Dismissed with Prejudice. All calendared dates are hereby vacated and the Clerk is directed to close the file. 17 18 19 IT IS SO ORDERED. November 17, 2016 DATED: _______________________ By: _______________________________________ THE HONORABLE HOWARD R. LLOYD Magistrate Judge 20 21 22 23 24 25 26 27 28 3 NOTICE OF DISMISSAL

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