Opinion
CASE NO. 5:12-cv-02251-LHK
05-01-2013
J & J SPORTS PRODUCTIONS, INC., Plaintiff, v. CONG NGOC TRAN, Defendant.
Thomas P. Riley, SBN194706 LAW OFFICES OF THOMAS P. RILEY, P.C. Attorneys for Plaintiff J & J Sports Productions, Inc. LAW OFFICES OF VIK. TRAN By: ViK Attorneys for Defendant CONG NGOC TRAN, individually and d/b/a QUYNH LAN
Thomas P. Riley, SBN194706
LAW OFFICES OF THOMAS P. RILEY, P.C.
Attorneys for Plaintiff
J & J Sports Productions, Inc.
STIPULATION OF DISMISSAL OF PLAINTIFF'S COMPLAINT
AGAINST DEFENDANT CONG NGOC TRAN, individually and d/b/a QUYNH LAN
IT IS HEREBY STIPULATED by and between Plaintiff J & J SPORTS PRODUCTIONS, INC. and Defendant CONG NGOC TRAN, individually and d/b/a QUYNH LAN, that the above-entitled action is hereby dismissed without prejudice against CONG NGOC TRAN, individually and d/b/a QUYNH LAN and subject to the Court's jurisdiction to enforce the settlement agreement reached between the Parties.
IT IS FURTHER STIPULATED that provided no Party referenced above has filed a motion to reopen this action by October 3, 2014, the dismissal shall be deemed to be with prejudice.
This dismissal is made pursuant to Federal Rules of Civil Procedure 41(a)(1). Each Party referenced-above shall bear its own attorneys' fees and costs.
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LAW OFFICES OF THOMAS P. RILEY,P.C.
By: Thomas P. Riley
Attorneys for Plaintiff
J &J SPORTS PRODUCTIONS, INC.
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LAW OFFICES OF VIK. TRAN
By: ViKTran
Attorneys for Defendant
CONG NGOC TRAN, individually and d/b/a QUYNH LAN
IT IS SO ORDERED: The Clerk shall close the file.
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The Honorable Lucy H. Koh
United States District Court
Northern District of California
PROOF OF SERVICE (SERVICE BY MAIL)
I declare that:
I am employed in the County of Los Angeles, California. I am over the age of eighteen years and not a party to the within cause; my business address is First Library Square, 1114 Fremont Avenue, South Pasadena, California 91030. I am readily familiar with this law firm's practice for collection and processing of correspondence/documents for mail in the ordinary course of business.
On May 1, 2013, I caused to serve the following documents entitled:
STIPULATION OF DISMISSAL OF PLANTIFF'S COMPLAINT AGAINST DEFENDANT CONG NGOC TRAN, individually and d/b/a QUYNH LAN
On all parties referenced by unclosing a true copy thereof in a sealed envelope with postage prepaid and following ordinary business practices, said envelope was addressed to:
Mr. Vi Tran, Esquire
LAW OFFICES OF VI. K. TRAN
(Attorney for Defendant)
The fully sealed envelope with pre-paid postage was thereafter placed in our law firm's outbound mail receptacle in order that this particular piece of mail could be taken to the United States Post Office in South Pasadena, California later this day by myself (or by another administrative assistant duly employed by our law firm).
I declare under the penalty of perjury pursuant to the laws of the United States that the foregoing is true and correct and that this declaration was executed on May 1, 2013. at South Pasadena, California.
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VANESSA VENTURA