Case 2:23-cv-20757-SRC-JSA Document 6 Filed 10/30/23 Page 1 of 3 PageID: 55
VIKAS KHANNA 1
Attorney for the United States
DAVID V. SIMUNOVICH
Assistant United States Attorney
970 Broad Street, Suite 700
Newark, NJ 07102
Tel. (973) 645-2736
david.simunovich@usdoj.gov
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
UNITED STATES OF AMERICA
Petitioner, HON. STANLEY R. CHESLER
v. Civil Action No. 23-20757 (SRC) (JSA)
MWW GROUP LLC d/b/a
MIKEWORLDWIDE,
Respondent.
STIPULATION OF DISMISSAL
WHEREAS, on September 28, 2023, the United States of America
commenced this proceeding via petition for summary enforcement of a civil
investigative demand;
WHEREAS the United States served the petition on respondent MWW Group
LLC; and
WHEREAS the Untied States and MWW Group LLC have reached an
agreement that resolves the issues in dispute in this matter;
1 Acting pursuant to authority conferred by 28 U.S.C. § 515.
Case 2:23-cv-20757-SRC-JSA Document 6 Filed 10/30/23 Page 2 of 3 PageID: 56
THEREFORE, the United States hereby DISMISSES this proceeding.
Pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure, this
dismissal is without prejudice, and is effective without a court order.
Dated: Newark, New Jersey
October 30, 2023
Respectfully submitted,
VIKAS KHANNA 2
Attorney for the United States
By: /s/ David V. Simunovich
DAVID V. SIMUNOVICH
Assistant United States Attorney
2 Acting pursuant to authority conferred by 28 U.S.C. § 515.
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Case 2:23-cv-20757-SRC-JSA Document 6 Filed 10/30/23 Page 3 of 3 PageID: 57
CERTIFICATE OF SERVICE
I, Assistant U.S. Attorney David V. Simunovich, hereby certify that on
October 30, 2023, I filed on ECF the foregoing stipulation of dismissal. In addition, I
sent the stipulation of dismissal by email to Respondent’s counsel Paul Piantino,
Esq. (PPiantino@fmglaw.com) and Katherine Mastrobuoni, Esq.
(Katherine.Mastrobuoni@fmglaw.com). I swear that the foregoing statements are
true and correct to the best of my ability and knowledge. I am aware that I am
subject to penalty for any willful misstatement herein.
Dated: October 30, 2023
Newark, New Jersey
/s/ David V. Simunovich
DAVID V. SIMUNOVICH
Assistant U.S. Attorney
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