UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA
March 30, 2011
BAY AREA PAINTERS AND TAPERS PENSION TRUST FUND, ET AL.,
ADVANCED INTERIOR SYSTEMS, INC., A CALIFORNIA CORPORATION; AND ROBERT LEE
BROWN, AN INDIVIDUAL,
The opinion of the court was delivered by: The Honorable Maxine M. Chesney United States District Court Judge
PLEASE TAKE NOTICE that pursuant to F.R.C.P. Rule 41(a)(1)(ii), Plaintiffs BAY AREA PAINTERS AND TAPERS PENSION TRUST FUND, et al., and Defendants ADVANCED INTERIOR SYSTEMS, INC., and ROBERT LEE BROWN, stipulate to the voluntarily dismissal, without prejudice, of Defendants ADVANCED INTERIOR SYSTEMS, INC., and ROBERT LEE BROWN, in this action.
ORDER RE: VOLUNTARY DISMISSAL WITHOUT PREJUDICE
1. The parties to this action have come to an agreement as to settlement of Plaintiffs' claim on contributions and other amounts found due by Defendants to Plaintiff Trust Funds, and have executed the attached Stipulation for Entry of Judgment ("Stipulation").
2. Pursuant to the terms of the Stipulation, the Court shall retain jurisdiction of this matter, and should Defendants default on their obligations under the Stipulation and fail to timely cure such default as provided in the Stipulation, Judgment may be immediately entered against Defendants and in favor of Plaintiffs upon the Declaration by a duly authorized representative of Plaintiffs.
3. Plaintiffs have not previously filed or dismissed any similar action against Defendants.
Respectfully submitted, Date: March 28, 2011 SALTZMAN & JOHNSON LAW CORPORATION By: /s/ Muriel B. Kaplan Attorneys for Plaintiffs
Based on the foregoing and GOOD CAUSE APPEARING, this action is dismissed, withou prejudice, and all dates in this matter are hereby vacated. The court shall retain jurisdiction of the action.
IT IS SO ORDERED.
PROOF OF SERVICE:
I, the undersigned, declare:
I am a citizen of the United States and am employed in the County of San Francisco, State of California. I am over the age of eighteen and not a party to this action. My business address is 44 Montgomery Street, Suite 2110, San Francisco, California 94104.
On March 28, 2011, I served the following documents:
VOLUNTARY DISMISSAL WITHOUT PREJUDICE
on the interested parties in said action by First Class U.S. Mail, by placing a true and exact copy of each document in a sealed envelope with postage thereon fully prepaid, in a United States Post Office box in San Francisco, California, addressed as follows:
Carl Patrick Stoll, Esq. Law Office of C. Patrick Stoll 2222 Francisco Drive, Suite 510-262 El Dorado Hills, California 95762
I declare under penalty of perjury that the foregoing is true and
correct and that this
declaration was executed on this 28th day
of March, 2011, at San Francisco, California.
Qui X. Lu
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