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  • Notice of Voluntary Dismissal of Suit

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    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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    DISTRICT OF NEW MEXICO

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    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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    © All Rights Reserved
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    107 views2 pages

    Notice of Voluntary Dismissal of Suit

    Uploaded by

    Basseem
    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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    © All Rights Reserved
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    of 2

    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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