STIPULATION FOR REQUEST FOR VOLUNTARILY DISMISSAL WITH PREJUDICE AND [PROPOSED] ORDER

JOSEPH C. SPERO, Chief Magistrate Judge.

MlKE DRIGGERS, JR., on one hand, and RANDAL WILLIAMS, on the other hand, entered into a Stipulation for Request for Dismissal with Prejudice and respectfully request the Court to enter into a dismissal as following:

1. EADGEAR, INC., GOFUNPLACES, INC. filed a Complaint in the above-captioned action on or about March 15, 2013 against RANDAL WILLIAMS, PROSPERITY FORMULA, LLC, JUBIMAX, LLC, JUBIMAX, INC., and AFFILIATE PRO, INC.;

2. RANDAL WILLIAMS filed a Complaint in the U.S. District Court for the Western District of Texas on or about February 21, 2013. On or about August 2, 2013, RANDAL WILLIAMS filed his Third Amended Complaint, naming defendants including EADGEAR HOLDINGS USA, INC., EADGEAR, INC., GOFUNPLACES, INC., SEEFREED TRAVEL, FRANCIS YUEN, CHARLES WANG, MIKE DRIGGERS, JR, GLEN JENSEN, LOURATA CHAN, CHILlN WU, XIN CHEN, JIMMY QI, SHERRY CHEN, and GOFUNPLACES, SRL. (hereinafter the "Western District of Texas Action");

3. RANDAL WILLIAMS has previously dismissed SEEFREED TRAVEL and GLEN JENSEN from the Western District of Texas Action. Further, RANDAL WILLIAMS moved for entry of default of judgment against GOFUNPLACES, SRL;

4. On or about February 3, 2014, the Western District of Texas Action was transferred to the U.S. District Court for the Northern District of California and this Court subsequently consolidated the Western District of Texas Action with the above-captioned action;

5. All parties have appeared and have filed answers in the above-captioned action, except EADGEAR HOLDINGS USA, INC. and GOFUNPLACES, SRL. RANDAL WILLIAMS hereby withdraws his motion for entry of default of judgment against GOFUNPLACES, SRL;

6. Some of the parties resolved their disputes amicably, leaving only the dispute between RANDAL WILLIAMS and MIKE DRIGGERS, JR., which remaining dispute has now been resolved pursuant to a written Settlement Agreement.

WHEREFORE, all parties respectfully request the Court to enter into an order to dismiss with prejudice the remaining dispute between RANDAL WILLIAMS and MIKE DRIGGERS, JR., and all matters that were or could have been asserted by each of them, and any and all claims by one party against the other, which shall have the effect of completely resolving all remaining disputes in this litigation. Each dismissed party shall bear its/his/her attorney's fees and case costs.

IT IS SO STIPULATED.

ORDER

GOOD CAUSE APPEARING, IT IS ORDERED that a DISMISSAL WITH PREJUDICE is entered into on 02/13/15, 2014 as to the complaints and claims, that were or could have been asserted, between MIKE DRIGGERS, JR. and RANDAL WILLIAMS. Each dismissed party shall bear its/his/her attorney's fees and case costs.

IT IS SO ORDERED