STIPULATION AND [PROPOSED] ORDER OF DISMISSAL

LAUREL BEELER, District Judge.

I. STIPULATION

After engaging in discovery and negotiation, Plaintiff Victoria Tulipani (hereinafter, "Plaintiff") and Defendant Samsung Electronics America, Inc. (hereinafter, "Defendant") have reached an individual settlement that will not require class certification or court approval of settlement.

Pursuant to Fed. R. Civ. P. 41(a)(1)(A)(ii), Plaintiff and Defendant, by and through their attorneys of record, therefore hereby stipulate to dismissal of any and all of Plaintiff's individual claims against Defendant, and stipulate to the proposed order attached hereto. This dismissal is without prejudice to any claims of the putative class members other than Plaintiff.

STIPULATED TO, AND DATED AND RESPECTFULLY SUBMITTED this 10th day of July, 2017.

Pursuant to Local Rule 5-1(i)(3), I hereby attest that concurrence in the filing of this document has been obtained from counsel for all parties, and that I will maintain records to support this concurrence by all counsel subject to this stipulation as required under the local rules.

III. [PROPOSED] ORDER PURSUANT TO STIPULATION

This matter came before the above-entitled Court on the parties' stipulation for dismissal with prejudice. After reviewing the files and records herein, and the Court having been fully advised, it is hereby:

ORDERED that Plaintiff's individual claims against Defendant are DISMISSED WITH PREJUDICE with each party to bear their own attorneys' fees, costs and expenses except as may be otherwise agreed to by the parties. This dismissal is without prejudice to any putative class claims.

IT IS SO ORDERED.