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STIPULATION OF CONDITIONAL DISMISSAL AND [PROPOSED] ORDER

4:16-CV-07346-HSG

LAW OFFICES OF ERIC M. LIGHTMAN

Eric M. Lightman (SBN 288791)

1254 Mission St.

San Francisco, CA 94103

Telephone: 415-295-4777

Fax: 415-795-4750

eric.m.lightman@gmail.com

Attorney for Plaintiff,

JEANNIE GONZALES

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

OAKLAND

JEANNIE GONZALES, an individual,

Plaintiff,

vs.

LABORATORY CORPORATION OF 

AMERICA HOLDINGS, a Delaware 

Corporation; and DOES 1–50,

Defendants.

Case No. 4:16-cv-07346-HSG

[Assigned to the Hon. Judge Haywood S. 

Gilliam]

STIPULATION OF CONDITIONAL 

DISMISSAL AND [PROPOSED] ORDER
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STIPULATION OF CONDITIONAL DISMISSAL AND [PROPOSED] ORDER

4:16-CV-07346-HSG

WHEREAS, on June 1, 2018, Plaintiff JEANNIE GONZALES (“Plaintiff”) and Defendant 

LABORATORY CORPORATION OF AMERICA HOLDINGS (“Defendant”) fully executed a 

Confidential Settlement, Waiver, and Release Agreement (“Agreement”) that will not be fully

performed until thirty-five (35) days from the date of the Agreement;

WHEREAS, the parties wish to dismiss the action upon completion of the thirty-five (35) day 

period, conditioned upon the satisfaction of all conditions that need to be satisfied under the 

Agreement;

WHEREAS, on May 29, 2018, the Court ordered the parties to file pre-trial documents or a

Stipulated Dismissal on or before June 1, 2018;

NOW, THEREFORE,

1. Pursuant to the terms set forth below, Jeannie Gonzales and Laboratory 

Corporation of America Holdings, by and through their respective attorneys of record, hereby 

stipulate to conditionally dismiss all of the claims in this action;

2. This dismissal is subject to satisfaction in full of all conditions precedent to

dismissal set forth in the Agreement;

3. During the thirty-five (35) day period and while this conditional dismissal is in 

effect, the June 11, 2018 trial is vacated; and

4. Once the thirty-five (35) day period has passed and the conditions precedent to 

dismissal have been satisfied, the parties shall file a stipulation of dismissal, pursuant to 

Federal Rule of Civil Procedure 41(a)(1)(A)(ii), and this conditional dismissal shall become a 

final dismissal with prejudice, each side to bear its own costs and attorneys’ fees.

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STIPULATION OF CONDITIONAL DISMISSAL AND [PROPOSED] ORDER

4:16-CV-07346-HSG

LAW OFFICES OF ERIC M. LIGHTMAN

Dated: June 1, 2018 By: /s/ Eric M. Lightman

Eric Lightman

Attorney for Plaintiff

JEANNIE GONZALES

K&L GATES LLP

Dated: June 1, 2018 By: /s/ Christopher K. Kondon

Christopher J. Kondon

Saman M. Rejali

Kate G. Hummel

Attorneys for Defendant

LABORATORY CORPORATION OF 

AMERICA HOLDINGS

PURSUANT TO THE ABOVE STIPULATION, IT IS SO ORDERED.

Dated: _______________________ _____________________________

 Honorable Haywood S. Gilliam, Jr.

 United States District Judge

6/4/2018