Free Motion to Dismiss - District Court of Colorado - Colorado

Case 1:04-cv-01056-EWN-MEH

Document 77

Filed 02/24/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 04-CV-1056-EWN-MEH

CONNIE J. REYNOLDS, Plaintiff, v. COBE CARDIOVASCULAR, INC., Defendant.

STIPULATION FOR DISMISSAL WITH PREJUDICE

Plaintiff Connie J. Reynolds and Defendant COBE Cardiovascular, Inc., by and through their respective undersigned attorneys, hereby move this Court for an Order of Dismissal with Prejudice of the pending action, and as grounds therefor, state as follows: 1. The Plaintiff and Defendant have reached an agreement to settle Plaintiff's claims

and all outstanding issues asserted in this action. 2. Plaintiff and Defendant hereby stipulate and agree that Plaintiff's Complaint filed

herein shall be dismissed with prejudice, and each party shall bear his or its own attorneys' fees and costs incurred in connection with this action. WHEREFORE, Plaintiff Connie J. Reynolds and Defendant COBE Cardiovascular, Inc. respectfully request that this Court issue an order dismissing this action with prejudice.

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Case 1:04-cv-01056-EWN-MEH

Document 77

Filed 02/24/2006

Page 2 of 2

Dated this 24th day of February, 2006.

OLSEN & BROWN LLC

ROTHGERBER JOHNSON & LYONS LLP

/s John R. Olsen John R. Olsen, Esq. Attorneys for Plaintiff 8362 Greenwood Drive Niwot, CO 80503 Telephone: (303) 652-1133 Fax: (303) 652-3701 [email protected]

/s Susan S. Sperber Susan S. Sperber, Esq. Attorneys for Defendant 1200 17th Street, Suite 3000 Denver, Colorado 80202 Telephone: (303) 623-9000 Fax: (303) 623-9222 [email protected]

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