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STIPULATION FOR DISMISSAL WITH PREJUDICE AND [PROPOSED] ORDER

4:16-CV-07346-HSG

Eric M. Lightman (SBN 288791)

LAW OFFICES OF ERIC M. LIGHTMAN

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 FOR DISMISSAL WITH 

PREJUDICE PURSUANT TO FED. R. CIV. 

P. 41(a)(1)(A)(ii) AND [PROPOSED] 

ORDER
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STIPULATION FOR DISMISSAL WITH PREJUDICE 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 would not be fully

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

WHEREAS, on June 1, 2018, the parties filed a Stipulation With Proposed Order for 

Conditional Dismissal subject to the subject to satisfaction in full of all conditions precedent to

dismissal set forth in the Agreement;

WHEREAS, on June 4, 2018, this Court ordered that 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 filed a Stipulation With Proposed Order for Conditional Dismissal;

WHEREAS all the conditions precedent to dismissal have been satisfied under the 

Agreement;

IT IS HEREBY STIPULATED AND AGREED by and between the parties to this action, 

through their respective attorneys, that pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil 

Procedure, this action, and all claims asserted herein by Plaintiff against Defendant, be dismissed 

with prejudice, each party to bear its own costs and attorneys’ fees.

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STIPULATION FOR DISMISSAL WITH PREJUDICE AND [PROPOSED] ORDER

4:16-CV-07346-HSG

LAW OFFICES OF ERIC M. LIGHTMAN

Dated: July 15, 2018 By: /s/ Eric M. Lightman

Eric Lightman

Attorney for Plaintiff

JEANNIE GONZALES

K&L GATES LLP

Dated: July 15, 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

7/16/2018