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STIPULATION OF DISMISSAL OF ALL CLAIMS AGAINST THE WASHINGTON POST COMPANY |
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David H. Angeli, OSB
No. 02024 Attorneys for Defendant The Washington Post Company
UNITED STATES DISTRICT COURT
AMERICAN BUDDHA, Civil No. 06-CV-3054-PA STIPULATION OF DISMISSAL OF ALL CLAIMS AGAINST THE WASHINGTON POST COMPANY STIPULATION OF DISMISSAL OF ALL CLAIMS AGAINST THE WASHINGTON POST COMPANY Pursuant to Fed. R. Civ. P. 41, Plaintiff American Buddha and Defendant The Washington Post Company (the "Post Company") (collectively, the "Parties), through their attorneys stipulate and agree that the Complaint against The Washington Post Company is hereby dismissed without prejudice. The Parties further stipulate and agree that in the event that Plaintiff re-files its complaint against the Post Company, the Post Company will waive any claim under Fed. R. Civ. P. 41(d) for the costs of defending this action up until the date of this stipulation. The Parties further stipulate and agree that the Post Company will, if necessary, accept service of a subpoena in this case, through undersigned counsel, without the need for personal service. By agreeing to accept service of a subpoena in this case, the Post Company does not waive any other objections, including but not limited to objections based on the attorney-client privilege and/or the attorney work product doctrine, to any subpoena that Plaintiff may serve. The parties will bear their own attorneys' fees and costs.
Charles Carreon (OSB No. 93469) Attorney for Plaintiff American Buddha David
H. Angeli (OSB No. 02024)
Kevin Hardy (pro hac vice) Attorney for Defendant The Washington Post Company Dated: November 28, 2006 |