UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
December 5, 2011
SITE UPDATE SOLUTIONS LLC PLAINTIFF,
ADOBE SYSTEMS, INCORPORATED ET AL., DEFENDANTS.
The opinion of the court was delivered by: Honorable Phyllis J. Hamilton States District Judge
STIPULATION AND [PROPOSED] ORDER TO DISMISS ALL CLAIMS BETWEEN SITE UPDATE SOLUTIONS LLC AND WAL-MART STORES , INC. WITHOUT PREJUDICE DEMAND FOR JURY TRIAL
Pursuant to Rule 41(a)(2) of the Federal Rules of Civil Procedure and the terms of a 2 separate agreement, the Plaintiff, Site Update Solutions LLC ("Site Update") and Defendant, Wal-3 Mart Stores, Inc. ("Wal-Mart") have agreed to dismiss all claims against each other in the above-4 captioned action. The parties, therefore, move this Court to dismiss the above-entitled cause and 5 all claims by Site Update against Wal-Mart and all claims by Wal-Mart against Site Update made 6 therein without prejudice. 7
The parties further move the Court to order that all costs and expenses relating to this 8 litigation (including attorney and expert fees and expenses) shall be borne solely by the party 9 incurring same.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
IT IS SO ORDERED
DATED: December __, 2011
Phyllis J. Hamilton United Judge
R F C GOLDSTEIN & LIPSKI, P.L.L.C. FOLEY & LARDNER LLP By: _/s/ Edward W. Goldstein_____________ By: _/s/ Victor de Gyarfas Edward W. Goldstein (Pro Hac Vice) Victor de Gyarfas 22 Attorneys for Plaintiff Attorneys for Defendant 23
I hereby attest pursuant to General Order 45.X.B that concurrence in the electronic filing of 3 this document has been obtained from the signatories. 4
Dated: December 5, 2011 /s/ Edward W. Goldstein________
Edward W. Goldstein
CERTIFICATE OF SERVICE
The undersigned hereby certifies that all counsel of record who are deemed to have 3 consented to electronic service are being served with a copy of this document via the Court's ECF 4 System. 5
s/ Edward W. Goldstein________
Edward W. Goldstein
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