Beneficial Innovations, Inc. v. Careerbuilder, LLC et al

Filing 175

MOTION to Dismiss Defendant Careerbuilder, LLC by Beneficial Innovations, Inc.. (Attachments: # 1 Text of Proposed Order)(Adams, Julien)

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BENEFICIAL INNOVATIONS, INC., Plaintiff, CASE NO. 2:09-cv-175 (TJW) vs. Jury Trial Demanded COMCAST CORPORATION, ET AL., Defendants. PLAINTIFF BENEFICIAL INNOVATIONS, INC.’S MOTION TO DISMISS CAREERBUILDER, LLC. COMES NOW Plaintiff Beneficial Innovations, Inc., pursuant to Federal Rule of Civil Procedure Rule 41(a)(1)(A)(i), and respectfully moves the Court to dismiss without prejudice all claims asserted by Plaintiff Beneficial Innovations, Inc., against Defendant Careerbuilder, LLC (“Careerbuilder”), and in support thereof would respectfully show the Court as follows: All matters in controversy between Plaintiff Beneficial Innovations, Inc., and Defendant Careerbuilder have been settled. Plaintiff Beneficial Innovations, Inc. therefore moves to dismiss all claims asserted against Careerbuilder without prejudice pursuant to Federal Rule of Civil Procedure Rule 41(a)(1)(A)(i). Plaintiff Beneficial Innovations, Inc., further moves that all attorneys fees and costs of court be borne by the party that incurred them. WHEREFORE, PREMISES CONSIDERED, Plaintiff Beneficial Innovations, Inc. prays that all claims asserted against Careerbuilder be dismissed without prejudice, with all attorneys’ fees and costs of court being borne by the party that incurred them. 1 Dated: January 19, 2012 Respectfully submitted, By: /s/ Julien A. Adams S. Calvin Capshaw State Bar No. 03783900 Elizabeth L. DeRieux State Bar No. 05770585 Brown McCarroll, L.L.P. 1127 Judson Road, Suite 220 Longview, TX 75601 Telephone: (903) 236-9800 Facsimile: (903) 236-8787 Email: Email: Of Counsel: Gregory S. Dovel CA State Bar No. 135387 Julien Adams CA State Bar No. 156135 Dovel & Luner, LLP 201 Santa Monica Blvd., Suite 600 Santa Monica, CA 90401 Telephone: 310-656-7066 Facsimile: 310-657-7069 ATTORNEYS FOR PLAINTIFF, BENEFICIAL INNOVATIONS, INC. 2 CERTIFICATE OF SERVICE I hereby certify that all counsel of record who are deemed to have consented to electronic service are being served this 19th day of January, 2012 with a copy of this document via the Court’s CM/ECF system per Local Rule CV-5(a)(3). /s/ Julien A. Adams Julien A. Adams 3

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