Free Motion to Dismiss - District Court of Colorado - Colorado

Case 1:04-cv-01025-ZLW-BNB

Document 114

Filed 06/28/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT IN AND FOR THE DISTRICT OF COLORADO Civil Action No.: 04-CV-1025-ZLW-BNB DALE ASMUSSEN, Plaintiff, v. MARVIN WADE, in his individual capacity, and CYNDI LOVELL, in her individual capacity, Defendants.

STIPULATED MOTION TO DISMISS WITH PREJUDICE

The Plaintiff, Dale Asmussen, and Defendants, Marvin Wade and Cyndi Lovell, through their respective counsel of record, and pursuant to Fed.R.Civ.P. 41(a)(2), respectfully move this Court for an Order dismissing this case with prejudice, and with each party to bear its own costs and attorney's fees. As grounds therefor, the parties state that they have reached a settlement of the case. WHEREFORE, the parties request that the Court enter an Order dismissing this case with each party to bear its own costs and attorneys fees. A proposed Order is attached.

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Case 1:04-cv-01025-ZLW-BNB

Document 114

Filed 06/28/2006

Page 2 of 2

DATED this 28th day of June, 2006. Respectfully submitted,

/s/ Cathy L. Cooper Cathy L. Cooper, Esq. Colorado Education Association 1500 Grant Street Denver, CO 80203 Telephone: 303-837-1500 Email: [email protected]

/s/ Matt Ratterman Matt Ratterman, Esq. Semple, Miller, Mooney & Farrington, P.C. 1120 Lincoln St., Ste. 1308 Denver, CO 80203 Telephone: 303-595-0941 Email: [email protected]

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