Alvarez v. Emergency Site Protection, LLC et al

Western District of Texas, txwd-5:2018-cv-01298

STIPULATION of Dismissal Without Prejudice by Josue Alvarez.

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION JOSUE ALVAREZ, § Individually and on behalf of all others § similarly situated, § § Plaintiff, § § vs. § NO. 5:18-CV-01298 § EMERGENCY SITE PROTECTION, § LLC, GRYPHON OILFIELD § SOLUTIONS, LLC, and SANCHEZ § OIL & GAS CORPORATION, § § Defendants. § STIPULATION OF DISMISSAL WITHOUT PREJUDICE Pursuant to Federal Rule of Civil Procedure 41, Plaintiff Josue Alvarez, Individually and on behalf of all others similarly situated ("Plaintiff"), and Defendant Emergency Site Protection, LLC ("ESP"), by and through their undersigned counsel, hereby agree and stipulate that the claims asserted against ESP in Plaintiff's First Amended Collective Action Complaint shall be dismissed in their entirety without prejudice, with each party to bear its own costs and fees. The Court shall retain jurisdiction over this matter as it pertains to Plaintiff's claims against Defendants Gryphon Oilfield Solutions, LLC and Sanchez Oil & Gas Corporation. Dated: May 2, 2019 ANDERSON ALEXANDER, PLLC By: /s/ Clif Alexander Clif Alexander Federal I.D. No. 1138436 Texas Bar No. 24064805 Lauren E. Braddy Federal I.D. No. 1122168 Texas Bar No. 24071993 Alan Clifton Gordon Federal I.D. No. 19259 Texas Bar No. 00793838 Carter T. Hastings Federal I.D. No. 3101064 Texas Bar No. 24101879 819 N. Upper Broadway Corpus Christi, Texas 78401 Telephone: (361) 452-1279 Facsimile: (361) 452-1284 Attorneys in Charge for Plaintiff and the Putative Class Members 2 Dated: May 2, 2019 Respectfully submitted, /s/ David B. Jordan Of Counsel: David B. Jordan (Attorney-in-Charge) Texas State Bar No. 24032603 Ashley D. Thomas LITTLER MENDELSON Texas State Bar No. 24090430 A PROFESSIONAL CORPORATION LITTLER MENDELSON 1301 McKinney, Suite 1900 A PROFESSIONAL CORPORATION Houston, Texas 77010 1301 McKinney Street, Suite 1900 713.652.4709 (Telephone) Houston, Texas 77010 713.951.9212 (Facsimile) 713.951.9400 (Telephone) 713.951.9212 (Facsimile) ATTORNEYS FOR DEFENDANT EMERGENCY SITE PROTECTION, LLC FIRMWIDE:164203996.1 071900.1004 3