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

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

Document 81

Filed 02/22/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-2328-RPM-CBS GREG JOSEPH GONZALES, by and through his next friend, JUNE BRAVO, Plaintiff, v. OFFICER BRETT C. TITUS, in his official and personal capacity, and CITY AND COUNTY OF DENVER, a municipality, Defendants. STIPULATION FOR DISMISSAL WITH PREJUDICE Plaintiff, Greg Joseph Gonzales, by and through his attorneys, Brian DeBauche, Brian DeBauche & Associates, LLC, and Defendant City and County of Denver, by and through its attorneys, the Office of the Denver City Attorney, Thomas Bigler, Assistant City Attorney, hereby agree and stipulate to dismissal of the within case with prejudice, as follows: 1. The City and County of Denver shall pay to Plaintiff Greg Joseph Gonzales, and

Brian DeBauche & Associates, LLC, 401 Kalamath Street, Denver, CO 80204, the total amount of Twelve Thousand Five Hundred and no/100 ($12,500), in complete and full settlement of any and all past and future claims of whatsoever kind and nature against Denver that are or may be related to the within case. 2. In consideration of the payment set forth in paragraph 2, herein, Plaintiff agrees to

dismiss the within case against the City and County of Denver, with prejudice, and that each party agrees to pay their own costs and attorney's fees. Plaintiff further agrees to execute and

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

Document 81

Filed 02/22/2006

Page 2 of 2

return to Defendants a general release of liability in substantially the same form as the General Release attached hereto as Exhibit "1". 3. The parties request that the Court approve the within stipulation of dismissal and

enter an Order dismissing this case, with prejudice. Dated this 22nd day of February, 2006. Respectfully submitted: BRIAN DEBAUCHE & ASSOCIATES, LLC Respectfully submitted: DENVER CITY ATTORNEY'S OFFICE s/ Thomas Bigler Thomas Bigler 201 West Colfax Avenue Denver, Colorado 80202 Telephone: (720) 865-8751 Facsimile: (720) 913-3182 Attorneys for Defendant City and County of Denver

s/ Brian DeBauche Brian DeBauche 401 Kalamath Street Denver, Colorado 80204 Telephone: (303) 571-5023 Facsimile: (303) 571-5043 Attorneys for Plaintiff

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