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Tramos International N.V. v. May

United States District Court, D. Nevada

July 17, 2017

TRAMOS INTERNATIONAL N.V., a Belgium corporation, Plaintiff,
v.
CHRISTINE A. MAY, R. PARKIN MAY; JAMES R. ESPOSITO, BERGDAHL ASSOCIATES, INC., a Nevada corporation, AND RPM TECHNOLOGY LLC, a Nevada limited-liability company, Defendants.

          CROWELL & MORING LLP Mark T. Jansen Attorneys for Plaintiff TRAMOS INTERNATIONAL N.V.

          GUNDERSON LAW FIRM Catherine A. Reichenberg Mark H. Gunderson Attorneys for Defendants CHRISTINE A. MAY, R. PARKIN MAY, JAMES R. ESPOSITO, BERGDAHL ASSOCIATES, INC., AND RPM TECHNOLOGY LLC,

          JOINT STIPULATION RE DISMISSAL OF PLAINTIFF'S CLAIMS FOR RELIEF WITH PREJUDICE, AND FOR ENTRY OF [PROPOSED] CONSENT DECREE AND PERMANENT INJUNCTION

          LARRY R. HICKS UNITED STATES DISTRICT JUDGE

         WHEREAS Plaintiff Tramos International N.V. (“Tramos”) having filed a Complaint, and an amended Complaint (hereafter, “Complaint”), in this action alleging Defendants Christine A. May, R. Parkin May, James Esposito, Bergdahl Associates, Inc., and RPM Technology LLC (“Defendants”) with, inter alia, copyright and trademark infringement, and such allegations having been wholly denied by the Defendants, and the Parties having entered into a confidential Settlement and Release Agreement;

The parties, by and through their counsel of record, stipulate and agree as follows:
1. That a [Proposed] Consent Decree and Permanent Injunction, in the form attached hereto as Exhibit 1, shall be and hereby is, entered and made enforceable, upon the terms set forth in that document.
2. That, subsequent to and conditioned upon entry of the Consent Decree and Permanent Injunction as an order of this Court, all claims for relief stated in the Complaint, as amended, and each of them shall be dismissed with prejudice, each party to bear their own costs and attorneys' fees.
3. The Consent Decree shall remain binding and enforceable notwithstanding the dismissal of this action with prejudice.
4. This Stipulation shall be binding on and inure to the benefit of the Parties to it, their successors, heirs, and assigns.

         IT IS SO STIPULATED.

         IT IS SO ORDERED.

         EXHIBIT 1

         [PROPOSED] CONSENT DECREE AND PERMANENT INJUNCTION

         The Court, having read and considered the Joint Stipulation Re Dismissal and Entry of Consent Decree and Permanent Injunction that has been executed by Plaintiff Tramos International N.V. (“Tramos”) and Defendants Christine A. May, R. Parkin May, James Esposito, Bergdahl Associates, Inc., and RPM Technology ...


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