Blake A. Field VS Google, Inc.,

Filing 68

Submission of PROPOSED ORDER filed by Defendant Google, Inc.. [Proposed] Order Directing the Clerk to Enter Judgment in Favor of Google Inc. Re: Attorney's Fees & Dismissing Without Prejudice Google Inc.'s Counterclaims (Kramer, David)

Blake A. Field VS Google, Inc.,

Doc. 68

Case 2:04-cv-00413-RCJ-GWF

Document 68

Filed 02/14/2006

Page 1 of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Kelly A. Evans Nevada Bar No. 7691 SNELL & WILMER L.L.P. 3800 Howard Hughes Parkway, Suite 1000 Las Vegas, NV 89109 Telephone [phone] Facsimile [phone] David H. Kramer (Admitted Pro Hac Vice) William O'Callaghan (Admitted Pro Hac Vice) WILSON SONSINI GOODRICH & ROSATI Professional Corporation 650 Page Mill Road Palo Alto, CA 94304-1050 Telephone [phone] Facsimile [phone] Attorneys for Defendant GOOGLE INC. UNITED STATES DISTRICT COURT DISTRICT OF NEVADA BLAKE A. FIELD, Plaintiff, vs. GOOGLE INC., Defendant. No. CV-S-04-0413-RCJ-LRL [PROPOSED] ORDER DIRECTING THE CLERK TO ENTER JUDGMENT IN FAVOR OF GOOGLE INC. RE: ATTORNEY'S FEES & DISMISSING WITHOUT PREJUDICE GOOGLE INC.'S COUNTERCLAIMS

AND RELATED COUNTERCLAIMS

Whereas, on January 19, 2006, the Clerk entered judgment in this action in favor of Google pursuant to an Order of this Court dated January 19, 2006 granting Google's Motion for Summary Judgment; Whereas, on January 26, 2006, defendant Google Inc. ("Google") and plaintiff Blake A. Field ("Field") jointly submitted a stipulation pursuant to Local Rules 6-2, 7-1 and 54-16 seeking
[PROPOSED] ORDER RE: ATTORNEY'S FEES AND DISMISSAL OF COUNTERCLAIMS Case No. CV-S-04-0413-RCJ-LRL

-1-

2820203_1.DOC

Dockets.Justia.com

Case 2:04-cv-00413-RCJ-GWF

Document 68

Filed 02/14/2006

Page 2 of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

entry of a judgment in defendant Google's favor (a) providing for an award of Google's attorney's fees and costs incurred in this action; and (b) providing that Google's counterclaims be dismissed without prejudice pursuant to stipulation and Federal Rule of Civil Procedure 41(a)(1); and Whereas, the parties appeared before the Court for a hearing on February 13, 2006 to address the matters raised by the parties' stipulation. Based upon the positions of the parties, and good cause appearing therefor, IT IS HEREBY ORDERED THAT: (1) The clerk shall enter judgment in defendant Google's favor as the prevailing party

against plaintiff Field in the amount of $25,000.00 for attorney's fees and costs incurred in this action; and (2) Google's counterclaims are dismissed without prejudice pursuant to stipulation and

Federal Rule of Civil Procedure 41(a)(1). SO ORDERED. _____________________________________ Honorable Robert C. Jones UNITED STATES DISTRICT COURT JUDGE DATED:

Approved as to Form: By: __/s/ Blake Field Blake Field, Pro Se Approved as to Form: By: __/s/ David H. Kramer David H. Kramer Attorneys for Defendant Google Inc.

[PROPOSED] ORDER RE: ATTORNEY'S FEES AND DISMISSAL OF COUNTERCLAIMS Case No. CV-S-04-0413-RCJ-LRL

-2-

2820203_1.DOC

Case 2:04-cv-00413-RCJ-GWF

Document 68

Filed 02/14/2006

Page 3 of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DATED: February 14, 2006

CERTIFICATION I, David H. Kramer, am the ECF User whose identification and password are being used to file this [PROPOSED] ORDER DIRECTING THE CLERK TO ENTER JUDGMENT IN FAVOR OF GOOGLE INC. RE: ATTORNEY'S FEES & DISMISSING WITHOUT PREJUDICE GOOGLE INC.'S COUNTERCLAIMS. I hereby attest that all parties have concurred in this filing.

WILSON SONSINI GOODRICH & ROSATI Professional Corporation

By: __/s/ David H. Kramer David H. Kramer Attorneys for Defendant Google Inc.

[PROPOSED] ORDER RE: ATTORNEY'S FEES AND DISMISSAL OF COUNTERCLAIMS Case No. CV-S-04-0413-RCJ-LRL

-3-

2820203_1.DOC

Case 2:04-cv-00413-RCJ-GWF

Document 68

Filed 02/14/2006

Page 4 of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

CERTIFICATE OF EMAIL AND U.S. MAIL I certify that a true and correct copy of the foregoing [PROPOSED] ORDER DIRECTING THE CLERK TO ENTER JUDGMENT IN FAVOR OF GOOGLE INC. RE: ATTORNEY'S FEES & DISMISSING WITHOUT PREJUDICE GOOGLE INC.'S COUNTERCLAIMS was served this 14th day of February 2006, via electronic mail to [e-mail] and by placing same in the United States mail, postage prepaid, addressed to the following: Blake A. Field 9805 Double Rock Drive Las Vegas, NV 89134 Pro Se Plaintiff

/s/ David H. Kramer Wilson Sonsini Goodrich & Rosati

[PROPOSED] ORDER RE: ATTORNEY'S FEES AND DISMISSAL OF COUNTERCLAIMS Case No. CV-S-04-0413-RCJ-LRL

-4-

2820203_1.DOC