IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

GAINESVILLE DIVISION

KIRK NIELSEN et al.,

Plaintiffs, CONSOLIDATED CASES

Case No. 4:20-cv-00236-RH-MJF

v.

RON DESANTIS, in his official as

Governor of the State of Florida, et al.,

Defendants.

__________________________________/

PLAINTIFF-INTERVENORS’ MOTION FOR VOLUNTARY DISMISSAL 

WITH PREJUDICE 

Plaintiff-Intervenors, DEBORAH C. GRUBB, DOUGLAS E. HALL, CARL 

F. MCCOY, JAMES K. KRACHT, DOLOR GINCHEREAU, and the FLORIDA 

COUNCIL OF THE BLIND, by and through the undersigned counsel, and pursuant 

to Rule 41(a)(2) of the Federal Rules of Civil Procedure, and the parties Settlement 

Agreement, hereby respectfully requests this Court enter an order dismissing this 

action with prejudice all claims they asserted against any party to the Litigation, and 

states as follows:

1. On June 10, 2020, this Court granted leave to intervene and deemed filed 

Intervenors Complaint in this case [DE - 216].

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Disability Independence Group, Inc. * 2990 Southwest 35th Avenue * Miami, Florida 33133

2. On July 31, 2020, the parties reached a settlement agreement, and 

pursuant to the settlement agreement, “pursuant to Federal Rule of Civil Procedure 

41(a)(2), Plaintiffs will file in the Litigation a motion for voluntary dismissal with 

prejudice of all claims they asserted against any party to the Litigation. It is the intent 

of the Parties—and Plaintiffs’ motion will request—that the Court not retain 

continuing jurisdiction to enforce this Agreement, or for any other purpose.

3. As such Plaintiff-Intervenors move to dismiss all claims they asserted 

against any party to the Litigation voluntarily. 

4. The requested dismissal is according to the terms of the settlement 

agreement between the Plaintiff-Intervenors and all Defendants, and the Court will 

not retain continuing jurisdiction to enforce this Agreement, or for any other purpose.

5. Plaintiff-Intervenors have agreed with all Defendants to the relief 

sought herein.

WHEREFORE, intervenors, DEBORAH C. GRUBB, DOUGLAS E. 

HALL, CARL F. MCCOY, JAMES K. KRACHT, DOLOR GINCHEREAU, and 

the FLORIDA COUNCIL OF THE BLIND, INC., respectfully request this Court

to dismiss all claims they asserted against any party to the Litigation with prejudice, 

and the Court will not retain continuing jurisdiction to enforce this Agreement, or 

for any other purpose.

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Disability Independence Group, Inc. * 2990 Southwest 35th Avenue * Miami, Florida 33133

CERTIFICATE OF COMPLIANCE 

Pursuant to Local Rule 7.1(B), the undersigned counsel has communicated in 

good faith with counsel for all Defendants, and the State Defendants and all have 

agreed to the relief requested herein.

By: s/ Matthew W. Dietz _____

Matthew W. Dietz, Esq.

Florida Bar No. 84905

CERTIFICATION OF WORD COUNT

I HEREBY CERTIFY, pursuant to Northern District of Florida Local Rule 

7.1(F), that this motion contains approximately 299 words.

By: s/ Matthew W. Dietz _____

Matthew W. Dietz, Esq.

Florida Bar No. 84905

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Disability Independence Group, Inc. * 2990 Southwest 35th Avenue * Miami, Florida 33133

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on August 4, 2020, I electronically filed the 

foregoing with the Clerk of the Court by using the CM/ECF system which will send 

notice of electronic filing to all parties and counsel of record in the herewith service 

list, or in some other authorized manner for those counsel or parties who are not 

authorized to receive notices electronically.

By: s/ Matthew W. Dietz 

MATTHEW W. DIETZ, ESQ.

Florida Bar No.: 00849

DISABILITY INDEPENDENCE GROUP, INC.

2990 Southwest 35th Avenue

Miami, Florida 33133

Tel: (305) 669-2822

Fax: (305) 442-4181

Mdietz@justDIGit.org

aa@justdigit.org

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