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

Case 1:04-cv-00722-LTB-MJW

Document 41

Filed 08/25/2005

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Case No.: 04-B-0722 (MJW) BARBARA J. ADRIAENS, Plaintiff, v. NORTH METRO DRUG TASK FORCE ("NMDTF"); THE CITY OF NORTHGLENN; THE CITY OF THORNTON; LIEUTENANT LORI MORIARTY, Commander of the NMDTF, in her individual capacity; DETECTIVE JORGE VILLEGOS, a law enforcement officer assigned to the NMDTF, in his individual capacity; SERGEANT JIM GERHARDT, a law enforcement officer assigned to the NMDTF, in his individual capacity; DETECTIVE CHARLES SCHOEPFTIN, a law enforcement officer assigned to the NMDTF, in his individual capacity; LEO GUILLIANO, Assistant Fire Chief of the Thornton Fire Department, in his individual capacity; RICK AMEND, Lieutenant of the Thornton Fire Department, in his individual capacity; JOHN DOE , a supervisor of the Northglenn/Thornton SWAT Team, in his individual capacity, Defendants.

STIPULATION AND AGREEMENT TO DISMISS WITH PREJUDICE

Plaintiff, Barbara Adriaens, by and through her attorneys, Perkins Coie, and the remaining Defendants, the North Metro Task Force, City of Thornton and the City of Northglenn, through their attorneys, Nathan, Bremer, Dumm & Myers, P.C., hereby stipulate and agree that the above captioned case shall be dismissed, with prejudice, pursuant to a Release and Settlement Agreement signed by the Plaintiff on August 8, 2005, each party to bear their own costs and attorney's fees. This Stipulation and Agreement concludes the case in as much as the other Defendants have already been dismissed.

Case 1:04-cv-00722-LTB-MJW

Document 41

Filed 08/25/2005

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Dated this _____ day of August, 2005.

s/Marni Nathan Kloster J. Andrew Nathan Karen R. Wells Marni Nathan Kloster Nathan, Bremer, Dumm & Myers, P.C. 3900 E. Mexico Avenue, Suite 1000 Denver, CO 80210 Tel: (303) 691-3737 Fax: (303) 757-5106 E-mails: [email protected]; [email protected]; [email protected] Attorneys for Defendants

s/Norton Cutler Norton Cutler Perkins Coie, LLP 1899 Wynkoop Street, Suite 700 Denver, CO 80202-1043 Tel: (303) 291-2300 Fax: (303) 291-2400 E-mail: [email protected] Attorneys for Plaintiff

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Case 1:04-cv-00722-LTB-MJW

Document 41

Filed 08/25/2005

Page 3 of 3

CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on August 25, 2005 , I electronically filed the foregoing Stipulation and Agreement to Dismiss With Prejudice with the Clerk of the Court using the Cm/ECF system which will send notification of such filing to the following e-mail address: Mark Silverstein, Esq. ­ [email protected] Norton Cutler, Esq. ­ [email protected] Herbert C. Phillips, Esq. ­ [email protected] David J. Bruno, Esq. ­ [email protected] Margaret Miller, Esq. ­ [email protected]

s/Marni Nathan Kloster J. Andrew Nathan Marni Nathan Kloster Attorneys for Defendant Nathan, Bremer, Dumm & Myers, P.C. 3900 E. Mexico Avenue, Suite 1000 Denver, CO 80210 Telephone: (303) 691-3737 Fax: (303) 757-5106 E-mails: [email protected]; [email protected]

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