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IT IS HEREBY STIPULATED AND AGREED by and between the parties through undersigned counsel that the above-captioned action is dismissed, with prejudice, pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii). The parties further stipulate that each party shall bear its own attorneys’ fees, costs and expenses.

PLAINTIFFS’ AMENDED STATUS REPORT REGARDING SERVICE UPON FOREIGN DEFENDANTS (06/18/21)

Plaintiffs, through their undersigned counsel, respectfully submit their Amended Status Report Regarding Service Upon Foreign Defendants. On June 1, 2021, pursuant to the Court’s May 26, 2021 Order (Dkt. 39), Plaintiffs submitted their Status Report Regarding Service Upon Foreign Defendants (Dkt. 41), reporting, inter alia, “[t]hat the process of serving the remaining foreign defendants remains underway.” The foreign defendants who have not been served are Inversiones Ibersuizas S.A.; Holcim Trading SA (F/K/A) Union Maritima Internacional SA; de Ruiter Ouderlande B.V.; and Las Pailas de Cemento S.A.U. (“Foreign Defendants”).*In addition, Plaintiffs informed the Court that Plaintiffs and LafargeHolcim had “reached an agreement in principle to settle this action in its entirety” and that the parties were “working diligently to consummate their settlement agreement and expect that the agreement will be completed on or before June 28, 2021.” (Dkt. 41). * Plaintiffs did not request that Clerk of the Court issue a summons to Defendant Unknown Subsidiary of the LafargeHolcim Group.

The settlement was finalized on June 17, 2021. Immediately after the settlement was finalized, Plaintiffs’ counsel instructed Plaintiffs’ vendor, TransPerfect Legal Solutions, to request cancellation of Hague Convention service upon the Foreign Defendants. TransPerfect has confirmed that its foreign partner has requested cancellation of service upon the Foreign Defendants. HCMLY h ttps://www.cubatrade.org/blog/2021/6/25/c3jwa630da63op8aldrdfsug9du9c4

GO FRAZ
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