PA Advisors, LLC v. Google Inc. et al

Filing 94

NOTICE of Voluntary Dismissal by PA Advisors, LLC (Attachments: #1 Text of Proposed Order)(LaValle, Amy)

PA Advisors, LLC v. Google Inc. et al

Doc. 94

Case 2:07-cv-00480-TJW

Document 94

Filed 01/24/2008

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PA ADVISORS, LLC Plaintiff, No. 2:07-cv-480-TJW v. JURY TRIAL DEMANDED GOOGLE INC., ET AL. Defendants. PLAINTIFF'S NOTICE OF VOLUNTARY DISMISSAL OF WPP GROUP PLC Pursuant to Federal Rule of Civil Procedure 41(a)(1)(i), Plaintiff PA Advisors, LLC ("PA Advisors") submits this notice of voluntary dismissal, without prejudice, of Defendant WPP Group plc. PA Advisors files this notice of dismissal subject to the representations made by WPP Group plc in its letter dated January 22, 2008 and the Declaration of Firouzeh Bahrampour dated December 20, 2007 attached thereto. Defendant WPP Group plc has not answered or filed a motion for summary judgment in this action. PA Advisors, therefore, asks the Court to dismiss all claims or causes of action asserted in this suit against Defendant WPP Group plc without prejudice to the right of PA Advisors to assert any such claims in the future.

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Dockets.Justia.com

Case 2:07-cv-00480-TJW

Document 94

Filed 01/24/2008

Page 2 of 3

Dated: January 24, 2008

Respectfully submitted, PA ADVISORS, LLC By: /s/ Amy E. LaValle Eric M. Albritton Texas State Bar No. 00790215 ALBRITTON LAW FIRM P.O. Box 2659 Longview, Texas 75606 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] David M. Pridham R.I. State Bar No. 6625 207 C North Washington Avenue Marshall, Texas 75670 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Amy E. LaValle Texas State Bar No. 24040529 THE LAVALLE LAW FIRM 3811 Turtle Creek Boulevard Suite 1620 Dallas, Texas 75219 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Of Counsel: Joseph Diamante JENNER & BLOCK LLP 919 Third Avenue, 37th Floor New York, New York 10022-3908 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] ATTORNEYS FOR PLAINTIFF PA ADVISORS, LLC

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Case 2:07-cv-00480-TJW

Document 94

Filed 01/24/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that the counsel of record who are deemed to have consented to electronic service are being served today with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3). Any other counsel of record will be served by electronic mail, facsimile transmission and/or first class mail on this same date.

Dated: January 24, 2008

/s/ Amy E. LaValle

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