Creighton v. Karamian et al

Filing 30

Agreed MOTION to Dismiss by Kristen Creighton, filed. Motion Docket Date 8/24/2010. (Attachments: # 1 Proposed Order)(Mahendru, Ashish)

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
KRISTEN CREIGHTON,

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Plaintiff,
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v.
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HOOMAN KARAMIAN a/k/a
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NIK RICHIE,
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JAMES GRDINA, JOHN GRDINA,
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FRANK DIMAGGIO and
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DIRTY WORLD, LLC d/b/a
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THEDIRTY.COM,
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Defendants.
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HOOMAN KARAMIAN,
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Counterclaimant,
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v.
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KRISTEN CREIGHTON,
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Counter Defendant.
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CIVIL ACTION NO. 10-1725
JURY

AGREED MOTION TO DISMISS
NOW COME Plaintiff, Kristen Creighton, and Defendants, Hooman Karamian
a/k/a Nik Richie, James Grdina, John Grdina, Frank DiMaggio and Dirty World, LLC
d/b/a the dirty.com, and respectfully move the Court to dismiss this cause of action and
counterclaim pursuant to Federal Rule of Civil Procedure 41(a)(1), and in support thereof
would respectfully show the Court as follows:

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I.
Plaintiff commenced this action by filing a complaint against Defendants Hooman
Karamian a/k/a Nik Richie, James Grdina, John Grdina, Frank DiMaggio and Dirty
World, LLC d/b/a thedirty.com.

Hooman Karamian filed a counterclaim against

Plaintiff.
The parties to this action have resolved their disputes on confidential terms and
agreed that the complaint and counterclaim be dismissed with prejudice. Therefore, all
matters in controversy between Plaintiff and Defendants have been settled and
compromised.
Accordingly, Plaintiff moves to dismiss all causes of action asserted or which
could have been asserted in this suit pursuant to Federal Rule of Civil Procedure 41(a)(1),
with prejudice to the right to pursue any such claims in the future.
Counterclaimant, Hooman Karamian a/k/a Nik Richie, moves to dismiss all
causes of action asserted or which could have been asserted in this suit pursuant to
Federal Rule of Civil Procedure 41(a)(1), with prejudice to the right to pursue any such
claims in the future.
Plaintiff and Defendants further move, as the parties agreed, that all costs and
expenses, including attorney’s fees, shall be borne by the party that incurred them.
WHEREFORE, PREMISES CONSIDERED, Plaintiff and Defendants pray that
this action be dismissed with prejudice and all costs and expenses, including attorney’s
fees, be borne by the party that incurred them.

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Respectfully submitted,

By: __/s/ Chris Bell_________________
Chris Bell
Texas Bar No. 00783631
The Kirby Mansion
2000 Smith Street
Houston, Texas 77002
[phone] (Telephone)
[phone] (Facsimile)
[e-mail]
Ashish Mahendru
Texas Bar No. 00796980
1601 Westheimer
Houston, Texas 77006
[phone] (Telephone)
[phone] (Facsimile)
[e-mail]
ATTORNEYS FOR PLAINTIFF

By: __/s/ Jeffrey Befort______________
Jeffrey L. Befort
Texas Bar No. 24025796
2603 Augusta Drive
Suite 810
Houston, Texas 77057
[phone] (Telephone)
[phone] (Facsimile)
[e-mail]
ATTORNEY-IN-CHARGE FOR
DEFENDANTS HOOMAN
KARAMIAN A/K/A NIK RICHIE
AND DIRTY WORLD, LLC
D/B/A THEDIRTY.COM

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By: __/s/ Shawn Raymond____________
H. Lee Godfrey
Texas Bar No. 08054000
Susman Godfrey LLP
1000 Louisiana, Suite 5100
Houston, Texas 77002
[phone] (Telephone)
[phone] (Facsimile)
[e-mail]
ATTORNEY-IN-CHARGE FOR
DEFENDANTS JAMES GRDINA,
JOHN GRDINA & FRANK
DIMAGGIO

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