Free Stipulation of Dismissal - District Court of Delaware - Delaware

Case 1:04-cv-00921-SLR

Document 102

Filed 05/18/2007

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE VURNIS L. GILLIS, Plaintiff, v. STAN TAYLOR, et al., Defendants. ) ) ) ) ) ) ) ) ) ) )

Civil Action No. 04-921-***

MOTION FOR APPROVAL OF STIPULATION REGARDING THE STATE DEFENDANTS' WITHDRAWAL OF THEIR MOTION TO DISMISS AND THE PLAINTIFF'S DISMISSAL OF CERTAIN STATE DEFENDANTS Comes now, State Defendants Stanley Taylor, Paul Howard, Thomas Carroll, Elizabeth Burris, David Holman ("NFN Holman"), Emily Stevenson, Ricky Porter ("NMN Porter"), Merissa McFadden, Jim Simms, Lise Merson, Mike Little, Edward Johnson, Maria Lyons ("NLN Maria"), Timothy Martin, Brian Engrem, and Osmar Sammander (the "State Defendants"), by and through the undersigned counsel and hereby move this Honorable Court (the "Motion") to approve and so order the Stipulation Regarding the State Defendants' Withdrawal of Their Motion to Dismiss and the Plaintiff's Dismissal of Certain State Defendants (the "Stipulation"), a copy of which is attached hereto as Exhibit "A," entered into by and among the Plaintiff, Vurnis L. Gillis (the "Plaintiff"), by his attorneys, Connolly Bove Lodge & Hutz LLP, and the State Defendants by their attorneys, Delaware Department of Justice. In support of the Stipulation, the State Defendants incorporate herein by reference the statements contained in the Stipulation.

Case 1:04-cv-00921-SLR

Document 102

Filed 05/18/2007

Page 2 of 3

WHEREFORE, the State Defendants respectfully request that this Honorable Court grant this Motion and approve the Stipulation. DEPARTMENT OF JUSTICE STATE OF DELAWARE /s/ Erika Y. Tross Erika Y. Tross (#4506) Deputy Attorney General 820 N. French Street, 6th Floor Wilmington, DE 19801 (302) 577-8400 Attorney for State Defendants

Dated: May 18, 2007

-2-

Case 1:04-cv-00921-SLR

Document 102

Filed 05/18/2007

Page 3 of 3

CERTIFICATE OF MAILING AND/OR DELIVERY I hereby certify that on May 18, 2007, I electronically filed Motion for Approval of Stipulation Regarding the State Defendants' Withdrawal of Their Motion to Dismiss and the Plaintiff's Dismissal of Certain State Defendants with the Clerk of the Court using CM/ECF which will send notification of such filing to the following: Zhun Lu, Esq. /s/ Erika Y. Tross Erika Y. Tross (#4506) Deputy Attorney General Delaware Department of Justice Carvel State Office Building 820 N. French Street, 6th Floor Wilmington, DE 19801 302-577-8400