Opinion
3:19-MC-80277-TSH
06-30-2022
In re Application of HRC-HAINAN HOLDING COMPANY, LLC, D&W HOLDING COMPANY, LLC, and HAINAN HRC HOSPITAL MANAGEMENT AND CONSULTING CO., LTD. Applicants, For Authorizing Discovery For Use In Foreign Proceedings Under 28 U.S.C. § 1782 YIHAN HU, HU-HANONE LLC, HU-HANTWO LLC, HU-HANTHREE LLC, BO HU, AND XIAOHONG HAN, Respondents
GRANT L. KIM LIMNEXUS LLP
GRANT L. KIM
LIMNEXUS LLP
STIPULATION REGARDING VOLUNTARY DISMISSAL WITH PREJUDICE
THOMAS S. HIXSON, JUDGE
Applicants HRC-Hainan Holding Company, LLC, D&W Holding Company, LLC, and Hainan HRC Hospital Management and Consulting Co., Ltd. (collectively, “Applicants”) and Respondents Yihan Hu, Hu-Hanone LLC, Hu-Hantwo LLC, Hu-Hanthree LLC, Bo Hu, and Xiaohong Han (collectively, “Respondents”) hereby stipulate as follows, by and through their counsel of record:
1. The parties to the underlying foreign dispute, for which the Section 1782 discovery was ostensibly to be used, have reached a global resolution of their disputes.
2. Accordingly, there is no pending or reasonably contemplated action in which any further discovery sought in this matter could be used.
3. The Parties herein have voluntarily dismissed the pending Ninth Circuit appeal, which was granted by the Ninth Circuit on June 24, 2022, thus returning jurisdiction to this Court.
4. Therefore, the Parties herein stipulate to the voluntary dismissal with prejudice of this action, with both sides to bear their own costs and fees.
WHEREFORE, the Parties request that the Court issue an order dismissing this action with prejudice, with both sides to bear their own costs and fees.
SO STIPULATED.
Grant L. Kim, counsel for Applicants whose ECF credentials are being used to file this Stipulation, hereby certifies that Katie Burghardt Kramer, counsel for Respondents, has approved this Stipulation and has consented to its filing with her signature.