Free Stipulation of Dismissal of Case - District Court of Colorado - Colorado

Case 1:04-cv-01040-LTB-CBS

Document 19

Filed 07/08/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-CV-1040-LTB-CBS RON L. BERRY, Plaintiff, v. MAVERICK STIMULATION CO., LLC, a Colorado limited liability company, Defendant. ______________________________________________________________________________ STIPULATION FOR DISMISSAL WITH PREJUDICE PURSUANT TO F.R.C.P. 42(a)(1)(ii) ______________________________________________________________________________ Plaintiff Ron L. Berry, ("Berry"), by and through his attorney, Christopher W. Jeffress, of COOK & JEFFRESS, P.C., and Defendant Maverick Stimulation Company., LLC ("Maverick"), by and through its attorneys Christopher J.W. Forrest and Andrew C. Iverson, of HAMILTON AND FAATZ, A PROFESSIONAL CORPORATION, pursuant to F.R.C.P. 42(a)(1)(ii), hereby stipulate that the above captioned shall be dismissed with prejudice pursuant to the parties' settlement of this matter. 1. On May 21, 2004, Berry filed his Complaint and Jury Demand in this matter

setting forth four claims: (i) Age Discrimination in Violation of 29 U.S.C. § 621, (ii) Tortious Interference with Prospective Business Advantage, (iii) Violation of C.R.S. § 8-2-113, and (iv) Negligence per se ­ Violation of C.R.S. § 8-2-113. 2. On December 10, 2004, Chief Judge Lewis T. Babcock dismissed Berry's second,

third and fourth claims for relief.

Case 1:04-cv-01040-LTB-CBS

Document 19

Filed 07/08/2005

Page 2 of 2

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The parties reached a settlement in this matter on June 27, 2005, and pursuant to

F.R.C.P. 41(a)(1)(ii) the parties hereby stipulate to the dismissal of this action with prejudice. 4. Accordingly, the parties request that the Court dismiss this matter with prejudice

and that each party is to pay its own costs and fees. DATED this 8th day of July 2005. Respectfully submitted, HAMILTON AND FAATZ, A Professional Corporation s/ Andrew C. Iverson Christopher J.W. Forrest Andrew C. Iverson 1600 Broadway, Suite 500 Denver, CO 80202-4905 Telephone: 303-830-0500 E-Mail: [email protected] Attorneys for Defendant Maverick Stimulation Company, LLC

COOK & JEFFRESS, P.C. s/ Christopher W. Jeffress Christopher W. Jeffress Attorneys for Plaintiff Ron L. Berry

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