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Notice of Voluntary Dismissal of Suit

This notice of voluntary dismissal summarizes that the plaintiffs O Centro Espirita Beneficente Uniao do Vegetal in the U.S. et al. are dismissing their case without prejudice against the defendants Chad Wolf et al. pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure. The rule allows plaintiffs to dismiss an action without a court order before the defendants have filed an answer or motion for summary judgment. As the defendants have not yet filed either document, the plaintiffs are providing notice to dismiss the case.

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270 views2 pages

Notice of Voluntary Dismissal of Suit

This notice of voluntary dismissal summarizes that the plaintiffs O Centro Espirita Beneficente Uniao do Vegetal in the U.S. et al. are dismissing their case without prejudice against the defendants Chad Wolf et al. pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure. The rule allows plaintiffs to dismiss an action without a court order before the defendants have filed an answer or motion for summary judgment. As the defendants have not yet filed either document, the plaintiffs are providing notice to dismiss the case.

Uploaded by

Basseem
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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Case 1:19-cv-01211-WJ-KK Document 9 Filed 04/06/20 Page 1 of 2

UNITED STATES DISTRICT COURT


DISTRICT OF NEW MEXICO

O CENTRO ESPIRITA BENEFICENTE


UNIAO DO VEGETAL IN THE U.S.,
JOSE CARLOS GARCIA, DANIELLE
HOUNSELL SILVA GARCIA, and
J.H.S.G., a minor, Case No.: 19-CV-1211-JFR-KK
Plaintiffs,
v.

CHAD WOLF, Acting Secretary of


Homeland Security; DEPARTMENT OF
HOMELAND SECURITY, an agency of
the United States; KENNETH T.
CUCCINELLI, Acting Director of U.S.
Citizenship and Immigration Services;
UNITED STATES CITIZENSHIP AND
IMMIGRATION SERVICES, an agency of
the United States; WILLIAM P. BARR,
U.S. Attorney General; CHRISTOPHER
WRAY, Director of FBI; FEDERAL
BUREAU OF INVESTIGATIONS, an
Agency of the United States, MIKE
POMPEO, U.S. Secretary of State; U.S.
DEPARTMENT OF STATE, an Agency of
the United States,

Defendants.

NOTICE OF VOLUNTARY DISMISSAL OF SUIT

Plaintiffs, by and through their attorney of record, Olsi Vrapi of Noble & Vrapi, P.A.,

pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, provide notice of the

dismissal of this action. As grounds therefor, Plaintiffs show the Court:

1. Pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, the plaintiff may

dismiss an action without a court order by filing a notice of dismissal before the opposing

party serves either an answer or a motion for summary judgment.

1
Case 1:19-cv-01211-WJ-KK Document 9 Filed 04/06/20 Page 2 of 2

2. Defendants have not yet filed and served either an answer or motion for summary

judgment.

3. Accordingly, Plaintiffs provide notice of the dismissal of this action without prejudice.

WHEREFORE, Plaintiffs, through their undersigned counsel, provide notice of the dismissal of

this action without prejudice. Pursuant to Rule 41(a)(1)(A)(i), no further action or court order is

necessary.

Respectfully Submitted, Dated this 6th day of April, 2020.

/s/ Olsi Vrapi


Olsi Vrapi
Attorney for Petitioner
Noble & Vrapi, P.A.
5931 Jefferson St. NE, Suite A
Albuquerque, NM 87109
Phone: (505) 352-6660
Fax: (505) 872-6120

CERTIFICATE OF SERVICE

I hereby certify that on April 6, 2020, I electronically filed the foregoing notice of
dismissal with the Clerk of the Court using the CM/ECF system, which will send notification to
Respondents’ counsel of record. In addition, a courtesy copy is being emailed to Tiffany
Walters, AUSA.

/s/ Olsi Vrapi


Olsi Vrapi
Attorney for Petitioner

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