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

Case 1:03-cv-02328-RPM-CBS

Document 82

Filed 02/23/2006

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF COLORADO Civil Action No. 03-cv-2328-RPM-OES GREG JOSEPH GONZALES, by and through his next friend, JUNE BRAVO Plaintiffs, v.

OFFICER BRETT C. TITUS, in his official and personal capacity, and CITY AND COUNTY OF DENVER, Defendants.

STIPULATION FOR DISMISSAL WITH PREJUDICE

Plaintiff, GREG JOSEPH GONZALES, by and through his next friend, JUNE BRAVO, and by his attorney, BRIAN DEBAUCHE, and Defendant OFFICER BRETT C. TITUS, by his attorney ERIC M. ZIPORIN, of the law firm of SENTER GOLDFARB & RICE, L.L.C. and DAVID J. BRUNO of the law firm of BRUNO BRUNO & COLIN, P.C., and pursuant to Fed.R.Civ.P. 41(a)(1), hereby stipulate and agree as follows: 1. Any and all remaining claims for relief asserted against Defendant Brett C. Titus

as set forth in Plaintiff' Complaint and Jury Demand, Amended Complaint and Jury Demand, s Second Amended Complaint and Jury Demand, Third Amended Complaint and Jury Demand, and all other pleadings shall be dismissed with prejudice; 2. Each of the Parties shall bear responsibility for their own costs and attorneys fees

associated with the dismissal of all of the remaining claims for relief against Defendant Brett C. Titus; and

Case 1:03-cv-02328-RPM-CBS

Document 82

Filed 02/23/2006

Page 2 of 3

3.

The Court may enter an Order of Dismissal of all claims for relief against

Defendant Brett C. Titus with Prejudice concerning the above-captioned matter without further action from the Parties.

Respectfully submitted,

By: s/ Brian DeBauche Brian DeBauche, Esq. Brian DeBauche & Associates, L.L.C. 401 Kalamath Street Denver, CO 80204 Telephone: (303) 571-5023 Attorney for Plaintiff

By: s/ Eric M. Ziporin Eric M. Ziporin, Esq. Senter Goldfarb & Rice, L.L.C. 1700 Broadway, Suite 1700 Denver, Colorado 80290 Telephone: (303) 320-0509 Facsimile: (303) 320-0210 Attorney for Defendant Titus

By: s/ David Bruno David Bruno Bruno, Bruno & Colin, P.C. 1560 Broadway, Ste. 1099 Denver, CO 80202-5143 Telephone: (303) 831-1099 Attorney for Defendant Titus

2

Case 1:03-cv-02328-RPM-CBS

Document 82

Filed 02/23/2006

Page 3 of 3

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this _____ day of _____________, 2006, I electronically filed a true and correct copy of the above and foregoing STIPULATION FOR DISMISSAL WITH PREJUDICE with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following: Thomas Bigler Assistant City Attorney Office of the City Attorney 201 W. Colfax Ave., Dept. 1108 Denver, CO 80202

s/ Barbara Ortell E-mail: [email protected] Secretary for Attorney Eric M. Ziporin

3