Salas v. Facultatieve Technologies The Americas, Inc. et al
Filing
76
STIPULATION RE: DISMISSAL OF WAGE LOSS CLAIMS AND INCINERATOR SPECIALISTS, INC. signed by Chief Judge Lawrence J. O'Neill on October 4, 2019. (Munoz, I)
1
2
3
4
5
6
NATHANIEL R. LUCEY, Esq. (SBN 260796)
ERICKSEN ARBUTHNOT
152 North Third Street, Suite 700
San Jose, CA 95112
Tel: (408) 286-0880
Fax: (408) 286-0337
Attorneys for Defendants
FACULTATIEVE TECHNOLOGIES
THE AMERICAS, INC. and INCINERATOR
SPECIALISTS, INC.
7
8
UNITED STATES DISTRICT COURT
9
EASTERN DISTRICT OF CALIFORNIA
10
Case No. 1:17-CV-00335-LJO-BAM
JONATHAN SALAS,
11
STIPULATION RE: DISMISSAL OF
WAGE LOSS CLAIMS AND
INCINERATOR SPECIALISTS, INC.
Plaintiff,
12
v.
13
FACULTATIEVE TECHNOLOGIES
THE AMERICAS, INC., ET AL.,
14
Defendants.
15
16
17
COME NOW PLAINTIFF JONATHAN SALAS [“Plaintiff”] AND DEFENDANTS
18
FACULTATIEVE TECHNOLOGIES THE AMERICAS, INC. and INCINERATOR
19
SPECIALISTS, INC. [“Defendants”] and enter into the following stipulation:
20
1.
Plaintiff hereby withdraws his claim for lost wages, future lost wages and a loss in
21
22
earning capacity against Defendants. Plaintiff agrees to not introduce evidence or testimony at trial
23
regarding or relating to any lost wages, earnings and bonuses or any future lost wages, earnings,
24
bonuses or any loss in earning capacity. Plaintiff agrees to withdraw Victor Johnson as an
25
unretained expert, Plaintiff agrees that he shall not submit to the jury an instruction or jury verdict
26
27
28
requesting said damages listed above. This stipulation shall not prohibit Plaintiff from introducing
evidence of how his injuries cause him pain& suffering/ emotional distress at his work.
1
STIPULATION RE: DISMISSAL OF WAGE LOSS CLAIMS AND INCINERATOR SPECIALISTS, INC.
Salas v. Facultatieve, et al.
Case No. 1:17-CV-00335-LJO-BAM
1
2
3
4
2.
Plaintiff agrees to dismiss INCINERATOR SPECIALISTS, INC. as a Defendant
in this action without prejudice.
3.
Defendant INCINERATOR SPECIALISTS, INC. agrees, in exchange for its
5
dismissal, to waive its right to costs against Plaintiff.
6
IT IS SO STIPULATED
7
8
MASTAGNI HOLSTEDT, A.P.C.
DATED: October 1, 2019
By: /Grant A. Winter/_________________
GRANT A. WINTER
Attorney for Plaintiff
9
10
11
12
ERICKSEN ARBUTHNOT
DATED: October 1, 2019
By: /Nathaniel R. Lucey/_______________
NATHANIEL R. LUCEY
Attorney for Defendants Facultatieve
Technologies The Americas, Inc. and
Incinerator Specialists, Inc.
13
14
15
16
ORDER
17
18
Having reviewed the Stipulation set forth above, and FOR GOOD CAUSE APPEARING
19
THEREFORE, the above Stipulation is accepted, adopted and made the Order of the Court.
20
IT IS SO ORDERED.
21
22
23
24
IT IS SO ORDERED.
Dated:
/s/ Lawrence J. O’Neill _____
October 4, 2019
UNITED STATES CHIEF DISTRICT JUDGE
25
26
27
28
2
STIPULATION RE: DISMISSAL OF WAGE LOSS CLAIMS AND INCINERATOR SPECIALISTS, INC.
Salas v. Facultatieve, et al.
Case No. 1:17-CV-00335-LJO-BAM
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?