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STATE OF LOUISIANA
NO. 15 5166 DIVISION "A" 15
FILED:
DEPUTY CLERK
NOW INTO COURT, through undersigned counsel, come Plaintiffs Young Money
Entertainment, LLC and Dwayne Michael Carter, Jr. (collectively "Plaintiffs"); Defendants Cash
Money Records, Inc., Bryan Williams, and Ronald Williams (collectively, "Cash Money
Defendants); and Defendants UMG Recordings, Inc. and Universal Music Group, Inc.
(collectively "Universal Defendants")1, and jointly move this Honorable Court to dismiss, with
prejudice, all claims brought by Plaintiffs against Cash Money Defendants and Universal
By joining this motion, the Universal Defendants do not waive their objections to personal
jurisdiction. See, e.g., Commercial Union Ins. Co. v. CBC Temp. Staffing Servs., Inc., 2003-0480
(La. App. 1 Cir. 11/3/04), 897 So. 2d 652, 654 ("[I]t is well settled that [even] a general appearance
does not waive a pending declinatory exception.") (emphasis added) (citing cases).
1
Plaintiffs, Cash Money Defendants, and Universal Defendants advise that as all claims
have been fully settled and resolved by compromise as between (i) Plaintiffs, on one hand, and (ii)
the Cash Money Defendants and Universal Defendants, on the other hand.
this Honorable Court grant this joint motion and execute the attached proposed o er
2
Plaintiffs, Cash Money Defendants, and Universal Defendants advise that as all claims
have been fully settled and resolved by compromise as between (i) Plaintiffs, on one hand, and (ii)
the Cash Money Defendants and Universal Defendants, on the other hand.
WHEREFORE, Plaintiffs, Cash Money Defendants, and Universal Defendants ask that
this Honorable Court grant this joint motion and execute the attached proposed order.
2
Plaintiffs, Cash Money Defendants, and Universal Defendants advise that as all claims
have been fully settled and resolved by compromise as between (i) Plaintiffs, on one hand, and (ii)
the Cash Money Defendants and Universal Defendants, on the other hand.
WHEREFORE, Plaintiffs, Cash Money Defendants, and Universal Defendants ask that
this Honorable Court grant this joint motion and execute the attached proposed order.
2
CIVIL DISTRICT COURT FOR THE PARISH OF ORLEANS
STATE OF LOUISIANA
NO: 15-5166 DIVISION: A-15
VERSUS
FILED:
DEPUTY CLERK
JUDGMENT OF DISMISSAL
Considering the foregoing Joint Motion for Judgment of Dismissal filed by Plaintiffs
Young Money Entertainment, LLC and Dwayne Michael Carter, Jr. (collectively "Plaintiffs");
Defendants Cash Money Records, Inc., Bryan Williams, and Ronald Williams (collectively, "Cash
Money Defendants); and Defendants UMG Recordings, Inc. and Universal Music Group, Inc.
GRANTED. The Cash Money Defendants and the Universal Defendants are hereby dismissed,
with prejudice, from this action, with each party to bear his or its own costs.
3
CERTIFICATE OF SERVICE
I hereby certify that I have on this day forwarded a copy of the foregoii%t&all I n
counsel of record either by electronic mail, facsimile, or United States mail, postag prepaid add
properly addressed:
Howard E. King
Seth Miller
King, Holmes, Paterno & Soriano, LLP
1900 Avenue of the Stars, 25th Floor
Los Angeles, California 90067-4506
Bruce V. Schewe
Phelps Dunbar, LLP
365 Canal Street, Suite 2000
New Orleans, Louisiana 70130
DATED: 2018
Alysson L. Mills, #32904