Opinion
Case No. C-04-3580-MJJ.
September 6, 2005
BORIS FELDMAN, State Bar No. 128838, LEO P. CUNNINGHAM, State Bar No. 121605, MEREDITH E. KOTLER, (admitted pro hac vice), MARK T. OAKES, State Bar No. 234598, WILSON SONSINI GOODRICH ROSATI, Professional Corporation, Attorneys for Defendants, SYNOPSYS, INC., AART DE GEUS, STEVEN K. SHEVICK, and VICKI ANDREWS.
Michael K. Yarnoff, Radnor, PA, Lead Counsel for Lead Plaintiff and the Proposed Class.
GREEN WELLING LLP, San Francisco, CA, Robert S. Green, Liaison Counsel for Lead Plaintiff and the Proposed Class.
STIPULATION AND [PROPOSED] ORDER FOR DISMISSAL WITH PREJUDICE AND ENTRY OF FINAL JUDGMENT
WHEREAS, on January 24, 2005, plaintiffs Yeushyr Wu, Robert Wiederhold, Hosein Naaseh-Sahry, and Thomas Ratcliffe, individually and on behalf of the Sara Eastwood Family Trust (collectively the "Lead Plaintiff"), filed their Consolidated Amended Class Action Complaint (the "Consolidated Complaint") in the above-titled action; and
WHEREAS, on March 25, 2005, defendants Synopsys, Inc., Aart J. de Geus, Steven K. Shevick, and Vicki L. Andrews (collectively "Defendants") filed a motion to dismiss the Consolidated Complaint and also filed a motion for sanctions under Rule 11 of the Federal Rules of Civil Procedure; and
WHEREAS, on August 10, 2005, the Court entered an order granting Defendants' motion to dismiss the Consolidated Complaint without prejudice and denying Defendants' motion for sanctions; and
WHEREAS, Lead Plaintiff and Defendants have agreed to dismissal with prejudice in this action provided that each party bear his, her or its own costs and fees incurred in this action.
NOW, THEREFORE, subject to the Court's approval, Plaintiff and Defendants, by and through their respective counsel of record, hereby agree and stipulate to the following:
1. The Consolidated Complaint, and all claims contained therein, shall be dismissed with prejudice.
2. Each party shall bear his, her or its own fees and costs.
3. Final Judgment shall be entered in the form attached hereto as Exhibit A.
IT IS SO STIPULATED.
ORDER OF DISMISSAL WITH PREJUDICE
Based upon the parties' stipulation for dismissal with prejudice and entry of final judgment, and good cause therefore appearing, it is hereby ORDERED that:1. The Consolidated Complaint, and all claims contained therein, are dismissed with prejudice.
2. Each party shall bear his, her or its own fees and costs.
3. Final Judgment shall be entered in the form attached hereto as Exhibit A.