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

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

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Filed 11/04/2005

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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 OF ALL STATE CLAIMS 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 Defendant THE CITY AND COUNTY OF DENVER, by their attorney, THOMAS G. BIGLER, and pursuant to Fed.R.Civ.P. 41(a)(1), hereby stipulate and agree as follows: 1. Any and all state claims for relief asserted against all Defendants as set forth in

Plaintiff's Complaint and Jury Demand, Amended Complaint and Jury Demand, 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 state claims; and

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

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3.

The Court may enter an Order of Dismissal of all state claims against all

Defendants 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

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

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By: s/ Thomas G. Bigler Thomas G. Bigler, Esq. Assistant City Attorney Office of the City Attorney 201 W. Colfax Avenue, Dept. 1108 Denver, Colorado 80202-5332 Telephone: (720) 913-3100 Attorney for Defendant City and County of Denver

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