`
`
`
`Benjamin W. Hattenbach (SBN 186455)
`bhattenbach@irell.com
`Ellisen S. Turner (SBN 224842)
`eturner@irell.com
`Christopher T. Abernethy (SBN 275986)
`cabernethy@irell.com
`Rosalyn M. Kautz (SBN 307831)
`rkautz@irell.com
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067
`Telephone: (310) 277-1010
`Facsimile:
`(310) 203-7199
`
`Attorneys for Defendant
`OSRAM SYLVANIA Inc.
`
`Brian Ledahl (SBN 186579)
`E-Mail: BLedahl@raklaw.com
`Neil A. Rubin (SBN 250761)
`E-Mail: NRubin@raklaw.com
`Jacob Buczko (SBN 269408)
`E-Mail: JBuczko@raklaw.com
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard 12th Floor
`Los Angeles, CA 90025
`Telephone: (310) 826-7474
`Facsimile: (310) 826-6991
`
`Attorneys for Plaintiff
`Document Security Systems, Inc.
`
`
`
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`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`SOUTHERN DIVISION
`
`
`
`Case No. 2:17-cv-05184-JVS-JCG
`
`
`STIPULATION AND
`JOINT MOTION TO DISMISS
`WITH PREJUDICE
`
`
`Plaintiff,
`
`
`DOCUMENT SECURITY SYSTEMS,
`INC.,
`
`
`
`
`
`v.
`
`
`
`OSRAM GMBH; OSRAM OPTO
`SEMICONDUCTORS GMBH & CO.;
`OSRAM Licht AG; and OSRAM
`SYLVANIA INC.,
`
`
`
`
`Defendants.
`
`
`
`
`10457056
`
`
`
`- 1 -
`
`STIPULATION AND JOINT MOTION
`TO DISMISS WITH PREJUDICE
`Case No. 2:17-cv-05184-JVS-JCG
`
`
`
`Case 2:17-cv-05184-JVS-JCG Document 67 Filed 03/12/18 Page 2 of 3 Page ID #:685
`
`Pursuant to Rule 41(a) of the Federal Rules of Civil Procedure and the
`agreement of the Parties, Plaintiff Document Security Systems, Inc. ("DSS") and
`Defendant OSRAM SYLVANIA Inc. ("OSI"), by and through their counsel of
`record, hereby stipulate to the dismissal of the above-captioned litigation in its
`entirety, with prejudice, as follows:
`
`1. All claims and counterclaims that DSS asserted against OSI, and against
`un-served Defendants OSRAM GmbH, OSRAM Opto Semiconductors
`GmbH, and OSRAM Licht AG,1 in the above-captioned litigation are
`dismissed in their entirety, with prejudice.
`
`2. All claims and counterclaims that OSI asserted against DSS in the above-
`captioned litigation are dismissed in their entirety, with prejudice.
`
`3. The parties shall each bear their own costs and attorneys' fees associated
`with the above-captioned litigation.
`
` A
`
` proposed Order of Dismissal With Prejudice is filed concurrently herewith.
`
`
`DATED: March 12, 2018
`
`
`Respectfully submitted,
`
`/s/ Brian Ledahl /s/ Benjamin W. Hattenbach
`
`Brian Ledahl
`Benjamin W. Hattenbach
`RUSS AUGUST & KABAT
`IRELL & MANELLA LLP
`
`
`Attorneys for Plaintiff
`Attorneys for Defendant
`Document Security Systems, Inc.
`OSRAM SYLVANIA Inc.
`
`
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`
`1 Defendants OSRAM GmbH, OSRAM Opto Semiconductors GmbH, and
`OSRAM Licht AG were not served with the Complaint or First Amended Complaint
`and have not appeared in this litigation. As to these defendants, the dismissal with
`prejudice is pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure.
`STIPULATION AND JOINT MOTION
`TO DISMISS WITH PREJUDICE
`Case No. 2:17-cv-05184-JVS-JCG
`
`10457056
`
`
`
`- 2 -
`
`
`
`Case 2:17-cv-05184-JVS-JCG Document 67 Filed 03/12/18 Page 3 of 3 Page ID #:686
`
`ATTESTATION OF AUTHORIZATION
`
`
`
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`
`Pursuant to Central District of California Local Rule 5-4.3.4(a)(2)(i), I hereby
`certify that the content of this document is acceptable to Brian Ledahl, counsel for
`Plaintiff, and I have obtained his authorization to affix his electronic signature to
`this document.
`
`DATED: March 12, 2018
`
`
`
`
`
`
`By:
`
`
` /s/ Benjamin W. Hattenbach
`Benjamin W. Hattenbach
`
`
`
`10457056
`
`
`
`- 3 -
`
`STIPULATION AND JOINT MOTION
`TO DISMISS WITH PREJUDICE
`Case No. 2:17-cv-05184-JVS-JCG
`
`
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