CONCLUSION Based on the foregoing, Mr. Sater respectfully requests an Order vacating the Plaintiffs’ Rule 41(a)(1) Notices of Voluntary Dismissal without prejudice under Rule 60(b) and dismissing the Plaintiffs case with prejudice under Rule 41(b), or through the use of any other method that the Court deems appropriate. Dated: October 9, 2015 New York, NY MOSES & SINGER LLP Attorneys for Defendant Felix Sater By:___/s/___________________ Robert S. Wolf 405 Lexington Avenue New York, NY 10174 (212) 554-7525 (phone) (917) 206-4325 (fax) rwolf@mosessinger.com cc: All Parties via ECF

Appearances of counsel were as noted in the record. The Court having read and considered the briefs and papers of the parties that were submitted to the Court in connection with the Motion, and being otherwise fully advised and good cause appearing thereof, this Court hereby GRANTS Helwan’s Motion for Involuntary Dismissal and Orders that the First Amended Complaint of Plaintiff and Counter-Defendant Tahaya Misr Investment Inc. (“Plaintiff”, formerly doing business as The Globe Corporation or “Globe”) is dismissed with prejudice and on the merits pursuant to FRCP 41(b). IT IS SO ORDERED.

Under all of the facts, the Court finds that it should exercise its discretion under Rule 41(d), and hereby orders that Nuance pay Abbyy USA’s costs of $27,275 incurred by Abbyy USA in connection with the Wisconsin Action. Pursuant to Rule 41(d), this action will be stayed until such time as Nuance files proof of payment with the Court. Dated:____________ ____________________________ Hon. Jeffrey S. White, United States District Judge Case 3:08-cv-02912-JSW Document 8-2 Filed 07/22/2008 Page 2 of 6 i 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 22, 2008 I, electronically filed [PROPOSED] ORDER ON MOTION FOR COSTS PURSUANT TO F.R.C.P. 41(D) with the Clerk of Court by using the CM/ECF system which will send a notice of electronic filing to the following: Franklin M. Rubinstein Wilson Sonsini Goodrich & Rosati 1700 K Street NW Fifth Floor Washington, DC 20006-3817 202-973-8833 Fax: 202-973-8899 LEAD ATTORNEY ATTORNEY TO BE NOTICED Julie M. Holloway Wilson Sonsini Goodrich & Rosati 650 Page Mill Road Palo Alto, CA 94304 650-493-9300 Email: jholloway@wsgr.com LEAD ATTORNEY ATTORNEY TO BE NOTICED Marvin Craig Tyler Wilson Sonsini Goodrich & Rosati 900 South Capital of Texas Highway Sa Cimas IV Fifth Floor Austin, TX 78746-5546 512/338-5410 Fax: 512-338-5410 Email: ctyler@wsgr.com LEAD ATTORNEY ATTORNEY TO BE NOTICED Ron Eleazer Shulman Wilson Sonsini Goodrich & Rosati A Professional Corporation 650 Page Mill Road Palo Alto, CA 94304-1050 650/493-9300 Fax: 650-565-5100 Email: rshulman@wsgr.com LEAD ATTORNEY ATTORNEY TO BE NOTICED Scott Andrew She

PAUL TAHLOR, M.D., et ano., Plaintiffs, -against- AHS HOSPITAL CORPORATION, et aI., Defendants. Civil Action No. 2:08-CV-02042-WJM -MF CERTIFICATE OF SERVICE I, Paul B. Brickfield, Esq., local counsel for Relators, hereby certify that, via the Court's electronic filing system, on the date listed below, I caused each of the following documents to be filed with the Clerk of the Court and served on all counsel of record : Relators' Memorandum of Law in Opposition to Defendants' Motion Pursuant to Fed. R. Civ. P. 41(b) to Dismiss the Third Amended Complaint for Supposed Lack of Prosecution and Certification of Timothy J. McInnis, Esq. in Opposition to Motion to Dismiss the Third Amended Qui Tam Complaint Pursuant to Fed. R. Civ. P. 41(b) for Failure to Prosecute. I further certify that I caused a courtesy copy of the foregoing documents to be sent via U.S. mail to: Honorable William J. Martini , U.S.DJ. Martin Luther King Building & U.S. Courthouse 50 Walnut Street Newark, NJ 07101

Dismissal is therefore appropriate. Accordingly, the Court should dismiss Plaintiffs’ complaint pursuant to Rule 41(b) based on Plaintiffs’ failure to comply with the Court’s prior orders. B. Plaintiffs’ Claims Also Fail Under Rule 12(b)(1) Because Plaintiffs Lack Standing to Seek Injunctive Relief. It is clear that Plaintiffs’ claims also fail for lack of standing.

Mr. Sherman is not evading responding to discovery, which distinguishes the Exxon Corp., 102 F.3d at 432 case cited by Yahoo. III. CONCLUSION In conclusion, Plaintiffs respectfully requests that the Court dismiss Mr. Sherman’s individual claims without prejudice on the condition that Mr. Sherman REPLY TO MOTION TO DISMISS MR. SHERMAN’S CLAIMS WITHOUT PREJUDICE PURSUANT TO FED. R. CIV. P. 41(A)(2) PAGE 10 OF 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 K A Z E R O U N I L A W G R O U P , A P C 24 5 F IS C H E R A V E N U E , U N IT D 1 C O S T A M E S A , C A 9 26 26 not re-file his same claims against Yahoo, which essentially imposes a res judicata effect (see Marlow v. Winston & Strawn, 19 F.3d 300, 303 (7th Cir. 1994)), while allowing Plaintiff to receive any award that may be awarded to the class members if class certification is granted. However, should the Court be inclined to award attorneys’ fees to Yahoo and/or additional discovery if Mr. Sherman’s claims are to be dismissed without prejudice (or otherwise), the Plaintiffs respectfully request that the Court either: (i) dismiss Mr. Sherman’s individual claims with prejudice and not award any attorney fees to Yahoo or permit additional discovery from Mr. Sherman (see Design Trend Int'l Interiors, Ltd. v. Huang, 2007 U.S. Dist. LEXIS 6

And in the instant matter, Defendant is again moving for dismissal on the erroneous claim that Defendant has already litigated and secured in its favor – an adjudication on the merits in matter # 10-CV-8022-PCT-PGR, although the same Defendant denied being the ‘correct’ party in that matter. III. CONCLUSION Defendant is misguided in both its interpretation and requirements of Fed.R.Civ.P 41(b) pertaining to the court’s order regarding dismissal in matter # 10-CV-8022-PCT-PGR as well as Fed.R.Civ.P 12(b)(6) pertaining to the pleading requirements placed upon Plaintiff in the present matter. Accordingly, Defendant’s Motion to Dismiss should be denied.

Dated: HON. TERRY J. HATTER, JR. UNITED STATES DISTRICT JUDGE Case 8:16-cv-00530-TJH-MRW Document 52-2 Filed 04/27/17 Page 2 of 3 Page ID #:951 LOS_ANGELES/#26233 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 VEDDER PRICE (CA), LLP ATTORNEYS AT LAW LOS ANGELES CERTIFICATE OF SERVICE I hereby certify that on April 27, 2017, a copy of the foregoing [PROPOSED] ORDER GRANTING PLAINTIFF KARMA AUTOMOTIVE, LLC’S MOTION FOR VOLUNTARY DISMISSAL WITHOUT PREJUDICE PURSUANT TO FED. R. CIV. P. 41(A)(2) was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the court’s electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing.

Nevada Bar No. 12488 1160 Town Center Drive, Suite 330 Las Vegas, Nevada 89144 Attorneys for U.S. Bank National Trust Company As Trustee, Successor In Interest To Bank Of America Association, As Trustee For Lehman As Trust Mortgage Pass-Through Certificates 2006- 11 Its Successors And Assigns Case 2:16-cv-00539-APG-VCF Document 23 Filed 02/27/17 Page 4 of 5 {40974781;1}5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 A K E R M A N L L P 1 16 0 N .T O W N C E N T E R D R IV E , S U IT E 33 0 L A S V E G A S , N E V A D A 89 1 01 T E L .: (7 02 ) 6 34 -5 00 0 – F A X : (7 02 ) 38 0 -8 57 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that, on the 27th day of February, 2017, and pursuant to FRCP 5, I served via CM/ECF and/or deposited for mailing in the U.S. Mail a true and correct copy of the foregoing DEFENDANTS' MOTION TO DISMISS PURSUANT TO FED. R. CIV. P. 41(B) postage prepaid and addressed to: Priscilla Santos Cortez 4132 Calmoor Street National City, CA 91950 Laurel I. Handley, Esq. Jory C. Garabedian, Esq. ALDRIDGE PITE, LLP 520 South 4th St., Suite 360 Las Vegas, Nevada 89101 /s/Jill Sallade

See, e.g., Pagtalunan, 291 F.3d at 643. V. CONCLUSION For all of the foregoing reasons, the United States asks the Court to dismiss Plaintiff’s action against the United States under Fed. R. Civ. P. 41(b) and Fed. R. Civ. P. 37 for failure to prosecute, cooperate in discovery, and comply with the Court’s orders. The United States’ counterclaim Case 2:11-cv-00623-MCE-EFB Document 107-1 Filed 10/04/16 Page 11 of 12 12 Memorandum in Support of U.S.’s Motion to Dismiss for Failure to Prosecute and Cooperate in Discovery 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 against Plaintiff should be preserved for resolution by dispositive motion.