Envelope: 431 8602

1 [Counsel listed 0n nextpage]

7 SUPERIOR COURT OF THE STATE OF CALIFORNIA

8 COUNTY OF SANTA CLARA — UNLIMITED JURISDICTION
9
JAMES DAMORE, DAVID GUDEMAN, Case No.2 18CV321529
1 0
MANUEL AMADOR, STEPHEN
11 MCPHERSON, and MICHAEL BURNS, JOINT STIPULATION AND
individually and 0n behalf of all others [PROPOSED] ORDER DISMISSING
12 similarly situated, ENTIRE ACTION
13 . .

Plalntlffs, Dept: 1

14 Judge: Hon. Brian C. Walsh

V.
1 5

1 6
GOOGLE, LLC, a Delaware limited liability
company; and DOES 1-10,
17
Defendants.
1 8

19

20

21

22

23

24

25

26

27

28

Joint Stipulation and [Proposed] Order Dismissing Case N0. 18CV321529

DI!
nmuumwsaoupmc.
:
Entire Action
 HARMEET K. DHILLON (SBN: 207873)
harmeet@dhillonlaw.com
KRISTA L. BAUGHMAN (SBN: 264600)
kbaughman@dhillonlaw.com
GREGORY R. MICHAEL (SBN: 306814)
gmichael@dhillonlaw.com
KOOONCNUI-PUJNt—t
DOROTHY YAMAMOTO (SBN: 306817)
dorothy@dhillonlaw.com
DANTE G. QUILICI (SBN: 328107)
dquilici@dhillonlaw.com
DHILLON LAW GROUP INC.
177 Post Street, Suite 700
San Francisco, California 94108
Telephone: (415) 433-1700
Facsimile: (415) 520—6593
Attorneys for Plaintiffs James Damore,
David Gudeman, Stephen McPherson, and
Michael Burns, on behalf of themselves
and all others similarly situated
NNNNNNNNNHh—tr—AHh—ir—th—th—Ar—th—i
OONOM-PWNHOKDOONOm-PWNHO
Joint Stipulation and [Proposed] Order Dismissing
DIG
DHILLEIH LAW GROUP INC;
Entire Action
PAUL HASTINGS LLP
ZACHARY P. HUTTON (SBN: 234737)
zachhutton@paulhastings.com
PAUL A. HOLTON (SBN: 3 13047)
paulholton@paulhastings.com
101 California Street, Forty-Eighth Floor
San Francisco, California 941 11
Telephone: (415) 856-7000
Facsimile: (415) 856-7100
PAUL HASTINGS LLP
J.Al LATHAM (SBN: 07 1 605)
allatham@paulhastings.com
CAMERON W. FOX (SBN: 2181 16)
cameronfox@paulhastings.com
515 South Flower Street, Twenty-Fifth Floor
Los Angeles, California 90071
Telephone: (2 1 3) 683-6000
Facsimile: (2 1 3) 627-0705
PAUL HASTINGS LLP
BARBARA B. BROWN (D.C. #355420; CA pro hac)
barbarabrown@paulhastings.com
KENNETH M. WILLNER (D.C. #415906; CA pro hac)
kenwillner@paulhastings.com
ANNA KIM YOON (SBN: 292082)
annayoon@paulhastings.com
875 15th Street, N.W.
Washington, D.C. 20005
Telephone: (202) 551-1717
Facsimile: (202) 551-0177
Attorneys for Defendant Google LLC
2
Case N0. 18CV321529
 Joint Stipulation

In support 0f this Joint Stipulation, the Parties stipulate and agree as follows:

WHEREAS, on January 8, 2018, Plaintiffs James Damore (“Damore”) and David Gudeman

(“Gudeman”) initiated this action against Defendant Google LLC (“Google”) by filing the Class
KOOONONUI-PUJNt—t

Action Complaint;

WHEREAS, on April 18, 2018, Damore and Gudeman, joined by Plaintiffs Manuel Amador

(“Amador”), Stephen McPherson (“McPherson”), and Michael Burns (“Burns”), filed the First

Amended Class Action Complaint;

WHEREAS, 0n December 14, 2018, the Court accepted Damore’s and Gudeman’s stipulation

to arbitrate their claims and stayed this action with respect to their claims;

WHEREAS, 0n December 14, 2018, the Court accepted Amador’s voluntary dismissal Without

prejudice of his claims;

WHEREAS, Damore, Gudeman, and Google have since agreed t0 end the case as between

them;

WHEREAS, Burns is unable to proceed as a plaintiff in this action and seeks t0 voluntarily

dismiss Without prejudice his claims;

NNNNNNNNNr—th—th—AHh—ir—th—th—Ar—th—i

WHEREAS, in light of the foregoing and after careful consideration, McPherson seeks to

voluntarily dismiss Without prejudice his claims;

WHEREAS, the Parties agree that each party is to bear his 0r its own expenses incurred in
OOQONm-wat—Okomflom-bwwt—O

relation to this action, including costs and attorneys’ fees; and

WHEREAS, the Court did not waive court fees and costs for any party in this case;

IT IS HEREBY STIPULATED AND AGREED by and between the Parties, through their
respective attorneys of record, that: (1) all claims asserted by Damore in this action be dismissed With

prejudice; (2) all Claims asserted by Gudeman in this action be dismissed With prejudice, With the sole

exception that this dismissal with prejudice does not bar claims previously asserted by Gudeman in

the action titled John Doe v. Google, Ina, et al, Case No. CGC-16-556034 (SF Super. Ct), currently

on appeal, Case Nos. A1 57097, A158826 (Cal. Ct. App. 1st Dist), nor the entirety 0f the direct claims

upon which the Doe PAGA claims are based, t0 the extent the existence 0f such a direct claim is
3
Joint Stipulation and [Proposed] Order Dismissing Case N0. 18CV321529
DIG
DHILLEIH LAW GROUP INC;
Entire Action
 necessary to continue his status as an aggrieved employee With standing in the Doe case; (3) all claims

asserted by McPherson and Burns, in both individual and putative class capacities, be dismissed

without prejudice; and 4) this matter is dismissed in its entirety.

\DOOQONUl-bUJNt—t

//

//

Respectfully submitted,

WZW
Dated: May 7, 2020 DHILLON LAW GROUP INC.

By:
Harmeet K. Dhillon
Attorneys for Plaintiffs James Damore,
David Gudeman, Stephen McPherson, and Michael
Burns, on behalf 0f themselves and all others
similarly situated

Dated: May 7, 2020 PAUL HASTINGS LLP

,--

,% '

Egv-ft‘é"f.
j

er—w-n-w-“mw-
'

By:
NNNNNNNNNHHHHHHh—th—Ar—th—i

Kenneth M. Willner
Attorneys for Defendant Google LLC
[PROPOSED] ORDER
OONOUl-PUJNHOKOOONQUl-PWNHO
On the stipulation 0f the parties, and good cause appearing therefor,

IT IS HEREBY ORDERED that:

(1) all claims asserted in this action by Plaintiff James Damore are dismissed With

prejudice;

(2) all claims asserted by Plaintiff Gudeman in this action are dismissed with prejudice,

With the sole exception that this dismissal With prejudice does not bar claims

previously asserted by Gudeman in the action titled John Doe v. Google, Ina, et al,

Case No. CGC—16-556034 (SF Super. Ct.), currently on appeal, Case Nos. A1 57097,

A158826 (Cal. Ct. App. lst Dist), nor the entirety of the direct claims upon which the

4
Joint Stipulation and [Proposed] Order Dismissing Case N0. 18CV321529
DIG
DHILLEIH LAW GROUP INC;
Entire Action
 H Doe PAGA claims are based, t0 the extent the existence of such a direct claim is

necessary t0 continue his status as an aggrieved employee With standing in the Doe

case;

(3) all remaining claims asserted in this action (by Plaintiffs Stephen McPherson and

Michael Burns), in both individual and putative class capacities, are dismissed without
\DOOQONUI-PUJN

prejudice; and

(4) this matter is dismissed in its entirety.

IT IS SO ORDERED.

H O DATED: ,
2020
Honorable Brian C. Walsh
Judge 0f the Superior Court

NNNNNNNNNv—‘h—‘b—ir—‘r—Hr—tr—AH

OONGUl-PUJNt—‘OKDOOQOUI-bWNH

D
DHILLEIH LAW GROUP INC;
Joint Stipulation
Entire Action
and [Proposed] Order Dismissing Case N0. 18CV321529