Free Motion to Dismiss - District Court of California - California

Case 3:07-cv-02222-IEG-BLM

Document 36

Filed 09/10/2008

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1 AMAR L. THAKUR, CAL. BAR NO. 194025 JON E. MAKI, CAL. BAR NO. 199958 2 NICOLE M. LEE, CAL. BAR NO. 222344 CRYSTINA COATS, CAL BAR NO. 234301 3 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP A Limited Liability Partnership 4 Including Professional Corporations 12275 El Camino Real, Suite 200 5 San Diego, California 92130 Telephone: 858-720-8900 6 Facsimile: 858-509-3691 Email: [email protected] 7 [email protected] [email protected] 8 [email protected] 9 Attorneys for Plaintiff and Counterdefendant Bridgepoint Education, Inc. 10 11 12 13 14 BRIDGEPOINT EDUCATION, INC., 15 16 v. Plaintiff, CASE NO. 07 CV 2222 IEG (BLM) JOINT MOTION FOR DISMISSAL OF ACTION WITH PREJUDICE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

17 PROFESSIONAL CAREER DEVELOPMENT INSTITUTE, LLC, and 18 DOES 1-10, inclusive, 19 Defendants.

Honorable Irma E. Gonzalez Courtroom 1

20 PROFESSIONAL CAREER DEVELOPMENT INSTITUTE, LLC, 21 Counterclaimant, 22 v. 23 BRIDGEPOINT EDUCATION, INC., 24 Counterdefendant. 25 26 27 28
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JOINT MOTION FOR DISMISSAL OF ACTION WITH PREJUDICE 07cv2222-IEG(BLM)

Case 3:07-cv-02222-IEG-BLM

Document 36

Filed 09/10/2008

Page 2 of 3

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JOINT MOTION FOR DISMISSAL WITH PREJUDICE

WHEREAS, plaintiff and counterdefendant BRIDGEPOINT EDUCATION, INC.

4 ("BRIDGEPOINT") and defendant and counterclaimant PROFESSIONAL CAREER 5 DEVELOPMENT INSTITUTE, LLC ("PCDI"), (the "PARTIES") have entered into a Settlement 6 Agreement and Mutual Release (the "Agreement") which resolves the claims and defenses that 7 were or could have been asserted in this action; and 8 WHEREAS, the PARTIES agree this Court has jurisdiction over the subject matter

9 of this action and over all PARTIES to this action and consent that the Magistrate Judge should 10 retain jurisdiction over the Agreement; 11 NOW THEREFORE, IT IS HEREBY STIPULATED AND RESPECTFULLY

12 REQUESTED BY ALL PARTIES TO THIS ACTION, THROUGH THEIR COUNSEL that this 13 Court enter an Order which provides for: 1) dismissal of this action with prejudice, with each 14 PARTY to bear its own respective costs and attorneys' fees incurred in connection with this 15 action; and 2) retention of jurisdiction by the Magistrate Judge over the Agreement pursuant to the 16 Consent to Jurisdiction by a United States Magistrate Judge form signed by the PARTIES and 17 their counsel. 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 ///
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JOINT MOTION FOR DISMISSAL OF ACTION WITH PREJUDICE 07cv2222-IEG(BLM)

Case 3:07-cv-02222-IEG-BLM

Document 36

Filed 09/10/2008

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1 2 3 4 DATED: September 10, 2008 5 6 7 8 9 10 11 12 13 14 DATED: September 10, 2008 15 16 17 18 19 20 21 22 23 24 25 26 27 28
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IT IS SO STIPULATED.

SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

By

s/ Jon E. Maki [email protected] AMAR L. THAKUR JON E. MAKI NICOLE M. LEE CRYSTINA COATS Attorneys for Plaintiff and Counterdefendant BRIDGEPOINT EDUCATION, INC.

SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

By

s/

Sarah M. Shalf [email protected] JOHN E. FLOYD SARAH M. SHALF

Attorneys for Defendant and Counterclaimant PROFESSIONAL CAREER DEVELOPMENT INSTITUTE, LLC

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JOINT MOTION FOR DISMISSAL OF ACTION WITH PREJUDICE 07cv2222-IEG(BLM)