`
`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`ALEXANDRIA DIVISION
`
`RAI STRATEGIC HOLDINGS, INC. AND R.J.
`REYNOLDS VAPOR COMPANY
`
`Plaintiff,
`
`ALTRIA CLIENT SERVICES LLC; PHILIP
`MORRIS USA, INC.; ALTRIA GROUP, INC.;
`PHILIP MORRIS INTERNATIONAL INC.;
`and PHILIP MORRIS PRODUCTS S.A.
`
`Defendants.
`
`Case No. 1:20-cv-00393-LO-TCB
`
`STIPULATION OF DISMISSAL
`
`Pursuant to Rule 41(a)(l)(A)(ii) of the Federal Rules of Civil Procedure, RAI Strategic
`
`Holdings, Inc. and R.J. Reynolds Vapor Company (collectively, "Plaintiffs") and Defendants
`
`Altria Client Services LLC ("ACS"), Philip Morris USA, Inc. ("PM USA"), and Philip Morris
`
`Products S.A. ("PMPSA") stipulate that Defendants Altria Group, Inc. ("AGI") and Philip Morris
`
`International Inc. ("PMII") should be dismissed from this case without prejudice.
`
`WHEREAS, Plaintiffs served the Summons and Complaint on Defendants AGI and PMII
`
`on or about April 13, 2020.
`
`WHEREAS, those Defendants' responses to the Complaint are due on May 4, 2020.
`
`WHEREAS, Defendants AGI and PMII represent that they are each holding companies
`
`that have not engaged in the manufacture, use, sale, offer for sale or importation of any accused
`
`products.
`
`
`
`Case 1:20-cv-00393-LMB-WEF Document 18 Filed 05/05/20 Page 2 of 4 PagelD# 297
`Case 1:20-cv-00393-LMB-WEF Document 18 Filed 05/05/20 Page 2 of 4 PageID# 297
`
`WHEREAS, Defendants ACS, PM USA, and PMPSAagreethat they will not use the
`
`absence of AGI and/or PMII from the caseasa basis to resist discovery, and that they will not
`
`make anysubstantive argument during the case that is based, in whole or in part, on the absence
`
`of AGI and/or PMII fromthe case.
`
`WHEREAS, in viewofthe foregoing, Plaintiffs consent to the dismissal of AGI and PMII
`
`from this action, without prejudice.
`
`NOW, THEREFORE,Plaintiffs, PMII and AGI herebystipulate and agree as follows:
`
`l.
`
`All claims in this action against PMII and AGI are hereby dismissed without
`
`prejudice pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure.
`
`z,
`
`PMII and AGI submit and consentto the jurisdiction of this Court solely for the
`
`purposes of enforcingthis stipulation, and to adjudicate or resolve anydisputes regarding its terms,
`
`interpretation, application, or requirements. Plaintiffs, ACS, PM USA, and PMPSA submit and
`
`consent to the jurisdiction of this Court for the purposes of enforcing this stipulation, and to
`
`adjudicate or resolve any disputes regardingits terms, interpretation, application, or requirements.
`SO ORDEREDthis S
`dayof
`aad
`, 2020.
`
`
`bo
`
`
`
`Case 1:20-cv-00393-LMB-WEF Document 18 Filed 05/05/20 Page 3 of 4 PagelD# 298
`Case 1:20-cv-00393-LMB-WEF Document 18 Filed 05/05/20 Page 3 of 4 PageID# 298
`
`Dated: May1, 2020
`
`Respectfully submitted,
`
`By: /s/ Maximilian A. Grant
`Maximilian A. Grant (VSB No. 91792)
`LATHAM & WATKINS LLP
`555 Eleventh Street, N.W., Suite 1000
`Washington, DC 20004
`Telephone: (202) 637-2200
`Facsimile:
`(202) 637-2201
`max.grant@lw.com
`
`Counselfor Defendants Altria Client Services
`LLC,Altria Group, Inc., Philip Morris USA,
`Inc., Philip Morris International Inc., and
`Philip Morris Products S.A.
`
`By: /s/ David M. Maiorana
`David M. Maiorana (VA Bar No. 42334)
`Ryan B. McCrum
`JONES DAY
`901 Lakeside Ave.
`Cleveland, OH 44114
`Telephone: (216) 586-3939
`Facsimile: (216) 579-0212
`Email: dmaiorana@jonesday.com
`Email: rbmccrum@jonesday.com
`
`Stephanie E. Parker
`JONES DAY
`1420 Peachtree Street, N.E.
`Suite 800
`Atlanta, GA 30309
`Telephone: (404) 521-3939
`Facsimile: (404) 581-8330
`Email: separker@jonesday.com
`
`Anthony M. Insogna
`JONES DAY
`4655 Executive Drive
`Suite 1500
`San Diego, CA 92121
`Telephone: (858) 314-1200
`Facsimile: (844) 345-3178
`Email: aminsogna@jonesday.com
`
`John J. Normile
`JONES DAY
`
`
`
`Case 1:20-cv-00393-LMB-WEF Document 18 Filed 05/05/20 Page 4 of 4 PagelD# 299
`Case 1:20-cv-00393-LMB-WEF Document 18 Filed 05/05/20 Page 4 of 4 PageID# 299
`
`250 Vesey Street
`New York, NY 10281
`Telephone: (212) 326-3939
`Facsimile: (212) 755-7306
`Email: jjnormile@jonesday.com
`
`Counselfor Plaintiffs
`RAIStrategic Holdings, Inc.
`RJ. Reynolds Vapor Company
`
`
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