Free Motion to Dismiss - District Court of California - California

Case 3:08-cv-00045-BTM-CAB

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Filed 07/07/2008

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PINNOCK & WAKEFIELD, A.P.C. Michelle L. Wakefield, Esq. David C. Wakefield, Esq. 3033 Fifth Avenue, Suite 410 San Diego, CA 92103 Telephone: (619) 858-3671 Facsimile: (619) 858-3646 Attorneys for Plaintiffs

Bar #: Bar #:

200424 185736

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

OUTERBRIDGE ACCESS ASSOCIATION, SUING ON BEHALF OF DIANE CROSS; and DIANE CROSS, An Individual, Plaintiffs, v.

Case No.: 08cv0045 BTM (CAB) JOINT MOTION AND MOTION TO DISMISS ALL DEFENDANTS FROM PLAINTIFFS' COMPLAINT, ALL CROSS-COMPLAINTS AND PLAINTIFFS' COMPLAINT WITH PREJUDICE IN THEIR ENTIRETY.

14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ROSS DRESS FOR LESS, INC. d.b.a. ROSS DRESS FOR LESS #478; MANNA DEVELOPMENT GROUP, LLC d.b.a. PANERA BREAD #4279; MIRA MESA MARKETPLACE EAST, LLC; AND DOES 1 THROUGH 10, Inclusive, Defendants.

THIS JOINT MOTION IS HEREBY MADE AND IT IS HEREBY STIPULATED by and between OUTERBRIDGE ACCESS ASSOCIATION, SUING ON BEHALF OF DIANE CROSS; and DIANE CROSS, An Individual, Plaintiffs, on the one hand, and all Defendants, on the other, through their respective attorneys of record, that all Defendants be dismissed with Prejudice from Plaintiffs' Complaint, Case Number 08cv0045 BTM (CAB). Additionally, the parties hereby stipulate that all

Case 3:08-cv-00045-BTM-CAB

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Filed 07/07/2008

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cross-complaints filed in this action, as well as Plaintiffs' Complaint be dismissed with prejudice in their entirety.

THIS JOINT MOTION IS HEREBY MADE AND IT IS SO STIPULATED. Dated: July 3, 2008 PINNOCK & WAKEFIELD, A.P.C. By: s/ Michelle L. Wakefield Michelle L. Wakefield, Esq. Attorney for Plaintiffs E-mail: MichelleWakefield@ PinnockWakefieldLaw.com

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 By: s/Timothy G. McNulty Timothy G. McNulty, Esq. Attorney for Defendant MIRA MESA MARKETPLACE EAST, LLC E-mail: [email protected] Dated: July 3, 2008 By: s/Ernest Slome Ernest Slome, Esq. Attorney for Defendant MANNA DEVELOPMENT GROUP, LLC d.b.a. PANERA BREAD #4279 E-mail: [email protected] Dated: July 3, 2008 By: s/John M. Julius John M. Julius, Esq. Attorney for Defendant ROSS DRESS FOR LESS, INC. d.b.a. ROSS DRESS FOR LESS #478 E-mail: [email protected] Dated: July 3, 2008 LITTLER MENDELSON, A.P.C.

Lewis Brisbois Bisgaard & Smith LLP

MILBERG & DE PHILLIPS, P.C.