Free Motion to Dismiss - District Court of California - California

Case 3:07-cv-02291-IEG-BLM

Document 11

Filed 07/16/2008

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Amy B. Vandeveld, SBN 137904
LAW OFFICES OF AMY B. VANDEVELD 92101

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1850 Fifth Avenue, Suite 22
San Diego, California

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Telephone:
Facsimile: Attorney

(619) 231-8883
(619) 231-8329

for PAUL CLADY

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IN THE UNITED STATES DISTRICT COURT

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SOUTHERN DISTRICT OF CALIFORNIA

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15 16 17 18 19 20 21 22 23 24 25 26 27 28 IT IS HEREBY STIPULATED Plaintiff, Defendant, by and between PAUL CLADY, GROVE, L.P. ,
PAUL CLADY, Plaintiff,

Case No.: 07 cv 2291 lEG (BLM) JOINT MOTION DISMISSAL FOR

vs.
CNA FINANCIAL, INC. dba ECONO LUBE & TUNE #51 et. al.,
Defendants.

[F.R.Civ.P. Rule 41 (a) (1), (2)]

on the one hand, and on the other hand, attorneys

BUENA VISTA-LEMON

(hereinafter

"the Parties")

through

their respective agreed to resolve Defendant appeared

of record that said Parties have them by way of settlement.

the case between

CNA FINANCIAL,

INC. dba ECONO LUBE & TUNE #51 never

in the instant action. further stipulate that Magistrate Judge appointed Judge Barbara by the Court, the Parties but not the

The Parties L. Major,

or any other Magistrate

shall retain jurisdiction arising

over all disputes Agreement

between

out of the Settlement

including,

limited to, interpretation

and enforcement

of the terms of

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Case 3:07-cv-02291-IEG-BLM

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Filed 07/16/2008

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Settlement hereby

Agreement.

The terms of the Settlement

Agreement

are

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incorporated

in this Joint Motion

for Dismissal.

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The Parties further stipulate, pursuant to Federal Rules of
Civil Procedure 41(a) (1,2), that this Court enter a dismissal
lEG (BLM)

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of

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Plaintiff'sComplaint in USDC Case No. 07 cv 2291
its entirety and with prejudice. stipulate Plaintiff

in

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and BUENA VISTA-LEMON

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GROVE L.P. further

that each shall bear its, his or her to any claims they may have except as otherwise set

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own costs and fees with respect against

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each other in the instant action, Agreement.

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forth in the Settlement

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IT IS SO STIPULATED. LAW OFFICES OF AMY B. VANDEVELD

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DATED:

7/16/08

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S/Amv B. Vandeveld AMY B. VANDEVELD, Attorney for Plaintiff E-mail: [email protected]

KIMBALL TIREY & ST. JOHN LLP

DATED: By: CRAIG D. MC MAHON, Esq. Attorney for Defendant BUENA VISTA-LEMON GROVE L.P.

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07/16/2008 12:10 FAX --. Case 3:07-cv-02291-IEG-BLM

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B7/16/2888 lB:55

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PAGE 83

1 . Settlement Agreement.
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The terms of the

Settlement

AgreeJD.ent are

incorporated

in this Joint Motion for Dismissal.

The parties fur~her stipulate, pursuant to Federal Rules of

4 Civil frocedure 41(a) (1,2), that this Court enter a dismissal of
51 Plaintiff'S Complaint in USDC Case No. 07 cv 2291 IEG 6 I its entirety and with prejudice.
E'laintiff and (BLM) in

BUENA VJ:STA-LEMON its, his or her

7 I GROVE L. P. further stipulate that each 8

shall hea.l':

own costs and fees with respect

to any claims they may have

9 1 against each other in the instant action, except as otherwise set 10 forth in the Settlement Agreement.

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~~ IS SO S~POLar.RD.
LAW OFFICES OF AMY B. VANDEVELD

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"DATED:
.:J.

SJAmy B. Vandeveld

AMY B. VANDEVELD,
Attorney for flaintiff E-mail: [email protected] JOHN LLP

,

(;?

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M

«'

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By:

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07/16/2008

WED

11:51

[JOB NO. 6244]

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