Free Motion to Dismiss - District Court of California - California

Case 3:08-cv-00484-H-RBB

Document 10

Filed 06/19/2008

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LYNN HUBBARD, III, SBN 69773 SCOTTLYNN J HUBBARD IV, SBN 212970 2 DISABLED ADVOCACY GROUP, APLC 12 Williamsburg Lane 3 Chico, CA 95926 Telephone: (530) 895-3252 4 Fax: (530) 894-8244
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Attorneys for Plaintiff

BRIAN MILLS, SBN 216078 SNELL & WILMER, LLP 600 Anton Boulevard, Suite 1400 8 Costa Mesa, CA 92626 Telephone: (714) 427-7000 9 Fax: (714) 427-7799
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Attorney for Defendant Northgate Gonzalez

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

BARBARA J HUBBARD, Plaintiff, v.

Case No. 08 cv 0484 H (RBB) JOINT MOTION FOR DISMISSAL

NORTHGATE GONZALEZ, LLC dba 21 NORTHGATE SUPERMARKET #27; LOS ALTOS ­ TUSCON, LLC; BIG 22 ROCK PALERMO, LLC; BIG ROCK, LLC,
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Joint Motion for Dismissal of Defendant Northgate Gonzalez, LLC, et. al

Defendants.

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Hubbard, et al. v. Northgate Gonzalez, LLC, et al. Case No. 08cv 0484 H (RBB)

Case 3:08-cv-00484-H-RBB

Document 10

Filed 06/19/2008

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PURSUANT TO A SETTLEMENT AGREEMENT AND RELEASE, it is

2 hereby jointly requested, by plaintiff, BARBARA HUBBARD, and defendant, 3 NORTHGATE GONZALEZ, LLP dba NORTHGATE SUPERMARKET # 27 that 4 this Court enter a dismissal with prejudice of plaintiff's complaint in the above-entitled 5 action pursuant to Fed. R. Civ. P. 41. 6 7 8 9 10 11 12 13 Dated: June19, 2008 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Joint Motion for Dismissal of Defendant Northgate Gonzalez, LLC, et. al

The dismissal with prejudice shall dismiss all parties in the action in its entirety.

Dated: June 19, 2008

DISABLED ADVOCACY GROUP, APLC /s/ Lynn Hubbard III LYNN HUBBARD, III Attorney for Plaintiff Barbara Hubbard

SNELL & WILMER, LLP /s/ Brian Mills BRIAN MILLS Attorney for Defendant Northgate Gonzalez, LLC dba Northgate Supermarket #27

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Hubbard, et al. v. Northgate Gonzalez, LLC, et al. Case No. 08cv 0484 H (RBB)

Case 3:08-cv-00484-H-RBB

Document 10

Filed 06/19/2008

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PROOF OF SERVICE

2 STATE OF CALIFORNIA, COUNTY OF BUTTE 3

I, Lynn Hubbard III, am employed in the aforesaid County; I am over the age of 18 years and not a party to the within action; my business address is 12 Williamsburg Lane, 4 Chico, Butte County, California 95926.
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On June 19, 2008, I caused the document(s) described as: JOINT MOTION FOR DISMISSAL to be served on the interested parties in this action as follows: On all parties identified for Notice of Electronic Filing generated by the Court's CM/ECF system under the above referenced case caption and number on this date, in the following manner: The following is a procedure in which service of this document was effected: (xx ) ELECTRONIC SERVICE - by causing the document to be served via the Court's ECF Filing System. ( ) OVERNIGHT DELIVERY - by causing said envelope(s) to be delivered overnight via an overnight delivery service in lieu of delivery by mail to the addressee(s). ( ) FAX - by transmitting pursuant to Rules 2001 et seq., the above-described document(s) by facsimile machine (which complied with Rule 2003(3)). The transmission originated from facsimile phone number (530) 894-8244, and was reported complete without error. The facsimile machine properly issued a transmission report. ( ) PERSONAL SERVICE - by causing to be delivered such document by hand to the offices of the addressee(s).

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 17 /s/ Lynn Hubbard III 18 DATED: June 19, 2008 Lynn Hubbard III
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Joint Motion for Dismissal of Defendant Northgate Gonzalez, LLC, et. al

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Hubbard, et al. v. Northgate Gonzalez, LLC, et al. Case No. 08cv 0484 H (RBB)