UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

ROBERT BLAIR, 

Plaintiff, 

 v. 

DEVRY INC. and ROSS UNIVERSITY 

SCHOOL OF MEDICINE; DOES I-XX, 

inclusive, 

Defendants. 

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Case No.: 1:12-cv-02637 

Hon. Virginia Kendall

STIPULATION OF DISMISSAL

Plaintiff, Robert Blair, and Defendants, DeVry Inc. and Ross University School of 

Medicine School of Veterinary Medicine Ltd., hereby enter and agree to the following 

stipulation of dismissal of the above-captioned action: 

1. Plaintiff filed a six count complaint asserting two federal causes of action — (1) 

a claim under the Racketeer Influenced and Corrupt Organizations Act (“RICO”), 18 U.S.C. §§ 

1961-1968 (Count One, Cmplt. ¶¶ 57-80) and (2) a claim under the Higher Education Act 

(“HEA”), 20 U.S.C. §§ 1092, 1094 (Count Two, Cmplt. ¶¶ 81-86) — and four state law causes 

of action, sounding in (1) breach of contract (Count Three, Cmplt. ¶¶ 87-91), (2) 

negligence/negligent hiring, training and supervision (Count Four, Cmplt. ¶¶ 92-97); (3) 

intentional and negligent infliction of severe mental distress (Count Five, Cmplt. ¶¶ 98-103); and 

(4) injunctive and declaratory relief (Count Six, Cmplt. ¶¶ 104-110). 

Case: 1:12-cv-02637 Document #: 12 Filed: 06/18/12 Page 1 of 4 PageID #:45
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2. On June 1, 2012, Defendants filed a motion to dismiss the Complaint pursuant 

to Federal Rule of Civil Procedure 12(b)(6). Defendants also sent Plaintiff’s counsel a letter 

advising that it was Defendants’ position that the federal claims alleged in the Complaint were 

not warranted by existing law and that continued prosecution of such claims would be subject to 

Federal Rule of Civil Procedure 11. 

3. Plaintiff hereby stipulates and agrees to the dismissal of this action with 

prejudice as to the federal claims alleged in Counts One (“RICO”) and Two (“HEA”), and 

without prejudice as to the state law claims alleged in Counts Three through Six. 

4. Both parties shall bear their own costs and fees in this action. 

SO STIPULATED 

Dated: Chicago, Illinois 

 June 18, 2012 

Case: 1:12-cv-02637 Document #: 12 Filed: 06/18/12 Page 2 of 4 PageID #:46
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/s/ Jason J. Bach /s/ R. Ryan Stoll 

Jason J. Bach 

THE BACH LAW GROUP, PLLC 

2802 Flintrock Trace, Suite 255 

Austin, TX 78738 

Telephone: (312) 460-5603 

jbach@bachlawfirm.com 

Uma Bansal 

THE BLAKE HORWITZ LAW FIRM 

39 South LaSalle Street, Suite 1515 

Chicago, IL 60603 

Telephone: (312) 676-2100 

ubansal@bhlfattorneys.com 

Blake Wolfe Horwitz 

THE BLAKE HORWITZ LAW FIRM 

39 South LaSalle Street, Suite 1515 

Chicago, IL 60603 

Telephone: (312) 676-2100 

Facsimile: (312) 372-7076 

bhorwitz@hrbattorneys.com 

Attorneys for Plaintiff 

R. Ryan Stoll 

SKADDEN, ARPS, SLATE, 

 MEAGHER & FLOM LLP 

155 North Wacker Drive, Suite 2700 

Chicago, IL 60606 

Telephone: (312) 407-0700 

Facsimile: (312) 407-8533 

Ryan.Stoll@skadden.com 

Attorney for Defendants 

Case: 1:12-cv-02637 Document #: 12 Filed: 06/18/12 Page 3 of 4 PageID #:47
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CERTIFICATE OF SERVICE

I hereby certify that a copy of the above Stipulation of Dismissal was served upon the 

following counsel on June 18, 2012, via the Court's CM/ECF system: 

Jason J. Bach 

jbach@bachlawfirm.com 

Uma Bansal 

ubansal@bhlfattorneys.com 

Blake Wolfe Horwitz 

bhorwitz@hrbattorneys.com 

Dated: June 18, 2012 

 /s/ R. Ryan Stoll 

R. Ryan Stoll 

Attorney for Defendants 

Case: 1:12-cv-02637 Document #: 12 Filed: 06/18/12 Page 4 of 4 PageID #:48