UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
e.Digital Corporation,
Plaintiff,
v.
SanDisk Corporation,
Defendant.
Case Nos.: 3:12-cv-2698 DMS (WVG)
JOINT MOTION FOR VOLUNTARY
DISMISSAL OF ALL CLAIMS AND
COUNTERCLAIMS
Assigned to the Honorable
Judge Dana M. Sabraw
Courtroom 13A (Annex)
HANDAL & ASSOCIATES
750 B STREET, SUITE 2510
SAN DIEGO, CA 92101
TEL: 619.544.6400
FAX: 619.696.0323
TO THE CLERK OF THE UNITED STATES DISTRICT COURT FOR
THE SOUTHERN DISTRICT OF CALIFORNIA:
Plaintiff and Counter-defendant e.Digital Corporation (“Plaintiff”) and
Defendant and Counterclaimant SanDisk Corporation (“SanDisk” or “Defendant”)
hereby present this joint stipulation and notice of dismissal.
Plaintiff and Defendant are referred to collectively hereafter as the “Parties.”
The Parties hereby stipulate and agree as follows:
1) Plaintiff e.Digital Corporation hereby voluntarily dismisses all claims
brought in this matter against Defendant and Counterclaimant
SanDisk Corporation WITH PREJUDICE;
2) Defendant SanDisk Corporation hereby dismisses all counterclaims
brought in this matter against Plaintiff and Counter-defendant
e.Digital Corporation WITH PREJUDICE; and,
3) Each party shall bear its own costs and attorneys’ fees.
Thus, it is thereby respectfully requested, in accordance with Federal Rules
of Civil Procedure 41(a) and 41(c), that the Court enter an order as follows:
1) Plaintiff and Counter-defendant e.Digital Corporation’s claims made
in its Second Amended Complaint (Docket #70) against Defendant
and Counterclaimant SanDisk Corporation are dismissed WITH
PREJUDICE;
2) Defendant and Counterclaimant SanDisk Corporation’s counterclaims
made in its Answer to the Second Amended Complaint (Dkt #71)
against Plaintiff and Counter-defendant e.Digital Corporation are
dismissed WITH PREJUDICE; and,
3) Each party shall bear its own costs and attorneys’ fees.
Pursuant to Local Civil Rule 7.2, the parties hereto will separately submit a
Proposed Order granting the relief requested.
Case 3:12-cv-02698-DMS-WVG Document 76 Filed 05/27/15 Page 2 of 4
JOINT MOTION TO DISMISS CASE NO: 12-CV-2698 DMS (WVG) -3-
HANDAL & ASSOCIATES
750 B STREET, SUITE 2510
SAN DIEGO, CA 92101
TEL: 619.544.6400
FAX: 619.696.0323
HANDAL & ASSOCIATES
Dated: May 27, 2015 By: /s/ Pamela C. Chalk
Pamela C. Chalk
Attorneys for Plaintiff
e.Digital Corporation
JONES DAY
Dated: May 27, 2015
/s/ Randall E. Kay
Randall E. Kay
Gregory L. Lippetz
Joe C. Liu
Attorneys for Defendant SanDisk
Corporation
ATTESTATION OF E-FILED SIGNATURE
