Case 4:16-cv-07248-YGR Document 31 Filed 01/09/17 Page 1 of 2

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Rivers J. Morrell, Esq. [SBN 57849]

Isaac Yim, Esq. [SBN 279166]
LAW FIRM OF RIVERS J. MORRELL III
A Professional Corporation
27201 Puerta Real, Suite 470
Mission Viejo, California 92691
Telephone:
(949) 305-1400

Alan C. Brown [SBN 166099]

Day, Day and Brown
301 West First Street
Tustin, CA 92780-3108
(714) 832-4811 ext 228

Attorneys for Plaintiff BRYAN G. W. NASH

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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CASE NO. 4:16-cv-07248 - YGR

BRYAN G. W. NASH

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Plaintiff,

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vs.

STIPULATION AND [PROPOSED] ORDER

FOR DISMISSAL WITH PREJUDICE AN D
WITHDRAWAL OF PENDING MOTIONS

MICHAEL GOGUEN and DOES 1

through 50 inclusive,
Defendants.

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IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS:

1. Pursuant to Rule 41 (a) (1) (A) (ii)

of the Federal Rules of

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Civil Procedure, and subject to the Court's approval, the

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Plaintiff hereby dismisses with prejudice the complaint

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in this action, which is the subject of two pending

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motions

(a Motion To Strike and a Motion To Dismiss);

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05814-00001/8758727.1

-1-

STIPULATION AND [PROPOSED) ORDER FOR DISMISSAL

WITH PREJUDICE AND WITHDRAWAL OF PENDING MOTIONS

Case 4:16-cv-07248-YGR Document 31 Filed 01/09/17 Page 2 of 2

2. Subject to the approval by the Court of the dismissal

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with prejudice, the Defendant hereby withdraws the

pending Motion to Strike and the Motion to Dismiss; and

3. Each side is to bear his own costs and attorneys'

fees

incurred in this action.

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Respectfully submitted,

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DATE: January -c,'

LAW FIRM OF RIVERS J. MORRELL III

Corporation

2017

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By:

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RS J. MORRELL III
C Y. YIM
ALAN C. BROWN
Attorneys for Plaintiff,
Bryan G. W. NASH

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DATED: January

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QUINN EMANUEL URQUHART &

SULLIVAN, LLP

2017

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By:
BRUCE E. VAN DALSEM
DIANE M. DOOLITTLE
Attorneys for Defendant,
Michael Goguen

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ORDER

PURSUANT TO STIPULATION,

IT IS SO ORDERED.

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DATED:

January 9

2017

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THE HONORABLE YVONNE GONZALES ROGERS

UNITED STATES DISTRICT COURT JUDGE

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05814-00001/8758727.1

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STIPULATION AND [PROPOSED) ORDER FOR DISMISSAL

WITH PREJUDICE AND WITHDRAWAL OF PENDING MOTIONS