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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ABC International Inc.,

Plaintiff,

v.

GD Group USA Company d/b/a GD 

Medical Inc., and Yong Zhang,

Defendants.

Case No.: 1:20-cv-1579

Honorable Judge Robert M. Dow, Jr.

Magistrate Judge Gabriel A. Fuentes GD Group USA Company d/b/a GD 

Medical Inc., and Yong Zhang, 

Counter-Plaintiffs,

v.

ABC International, Inc.,

Counter-Defendant.

and

Eddie Ni,

Proposed Additional 

Counter-Defendant.

STIPULATION OF DISMISSAL

Plaintiff, Defendants, and Proposed Additional Counter-Defendant file this 

stipulation of dismissal under Federal Rule of Civil Procedure 41(a)(1)(A)(ii). 

1. Plaintiff is ABC International Inc., and Defendants are GD Group USA 

Company d/b/a GD Medical Inc., and Yong Zhang. Proposed Additional CounterDefendant is Eddie Ni.
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2. On March 4, 2020, Plaintiff sued Defendant.

3. Defendants have counter-claimed and filed a motion to add the Proposed 

Additional Counter-Defendant as an additional counter-claim defendant or third party

defendant.

4. Proposed Additional Counter-Defendant has filed a motion to dismiss the 

proposed counter-claims or third party claims which Defendants filed against him. That 

motion is currently pending.

5. The Plaintiff, Defendant, and Proposed Additional Counter-Defendant to 

this action (collectively the “Parties,” each of them a “Party”) hereby stipulate that all 

claims, counter-claims, affirmative defenses, and proposed counter-claims or third

party claims asserted in this case to date be and are dismissed without prejudice as set 

forth below, with the Parties to bear their own respective costs and attorneys’ fees.

6. This case is not a class action under Federal Rule of Civil Procedure 23, a 

derivative action under Federal Rule of Civil Procedure Rule 23.1, or an action related 

to an unincorporated association under Federal Rule of Civil Procedure Rule 23.2, and it 

is not governed by any federal statute that requires a court order for dismissal of the 

case.

7. No Party has previously dismissed any federal- or state-court action based 

on or including the same claims, affirmative defenses, counter-claims, or proposed 

counter-claims or third party claims presented in this case.

8. The above-stipulated dismissals are without prejudice, and with the 

Parties retaining the right to re-file their respective claims, affirmative defenses,
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counter-claims, and proposed counter-claims or third party claims which had been 

asserted in this case. In the event of any such refiling, any limitations period or other 

deadline is tolled so as to permit the filing and assertion of each opposing Party’s 

respective claims, affirmative defenses, counter-claims, or proposed counter-claims or 

third party claims, as the case may be, that are dismissed above by this Stipulation.

Respectfully submitted,

ABC International, Inc.

and Eddie Ni

By: /s/ Darrell J. Graham

One of said Plaintiff’s and 

said Proposed Additional 

Counter-Defendant’s 

Attorneys, on their behalf

Darrell J. Graham

ROESER TANNER GRAHAM 

LLC

2 N. Riverside Plz 

Suite 1850

Chicago, IL 60606

312.621.0301

dgraham@rtglaw.com

Dated: May 25, 2022

GD Group USA Company, 

doing business and sued as 

GD Medical, Inc.

By: /s/ Gregg I. Minkow

One of said Defendant’s 

Attorneys, on its behalf

Gregg I. Minkow

MINKOW & BERGMAN, LLC

161 N. Clark St.

Suite 1600

Chicago, IL 60601

847.489.6999

gminkow@

minkowbergman.com

Dated: May 25, 2022

Yong Zhang

By: /s/ Christopher E. Kentra

One of said Defendant’s 

Attorneys, on his behalf

Christopher E. Kentra

BURKE WARREN PC

330 N. Wabash Ave 

Suite 2100

Chicago, IL 60611

312.840.7000

ckentra@burkelaw.com

Dated: May 25, 2022
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CERTIFICATE OF SERVICE

I hereby certify that on this 25th day of May 2023, the above and foregoing was 

filed electronically with the Clerk of the Court using the CM/ECF system, which sent 

notification to all ECF registrants that are counsel of this record for this matter.

/s/ Darrell J. Graham