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Adobe Systems Inc. v. Johnson

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO)


November 17, 2010

ADOBE SYSTEMS INCORPORATED, PLAINTIFF,
v.
KATRINA JOHNSON F/K/A KATRINA KATRINA JOHNSON, ET AL., DEFENDANTS.

JOINT STIPULATION FOR DISMISSAL WITH PREJUDICE OF DEFENDANT SNOWDEN AND WITHDRAWAL OF DEFENDANTS' MOTION TO DISMISS

Plaintiff Adobe Systems Incorporated ("Plaintiff") and Defendants Katrina Johnson f/k/a Katrina Snowden, an individual ("Johnson"), and Royal Distribution, Inc. ("RDI") (collectively "Defendants"), by and through their respective counsel of record, hereby stipulate and agree as follows:

WHEREAS Plaintiff filed its Complaint against Defendants on or about August 13, 2010;

WHEREAS Defendants filed their Motion to Dismiss Katrina Johnson Pursuant to Fed. R. Civ. P. 12(b)(2) and 28 U.S.C. 1400(a); and to Dismiss Defendants for Improper Venue Under 28 U.S.C. 1391(b); or in the Court's Discretion, to Transfer Venue Pursuant to 28 U.S.C. § 1404(a) ("Motion") on or about October 25, 2010;

WHEREAS Defendant Johnson has sworn to her part-time position at Defendant RDI and lack of managerial or decision-making duties;

WHEREAS Defendant Johnson understands that the statements made in her declaration submitted in connection with Defendants' Motion are subject to the penalty of perjury;

WHEREAS Defendants acknowledge that the Court has personal jurisdiction over Defendant RDI;

WHEREAS Defendants acknowledge that venue is proper in the Northern District of California over the claims asserted against Defendant RDI;

WHEREAS each party will bear its own fees and costs in connection with Plaintiff's claims against Defendant Johnson;

WHEREAS the Parties stipulate that Defendant RDI shall have until November 29, 2010, to file an Answer to the Complaint; and

20101117

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