Carden et al v. Chenega Security & Protection Services, LLC

Filing 112

STIPULATION and ORDER 111 for Dismissal signed by Judge William B. Shubb on 8/2/2011. This action is DISMISSED with prejudice pursuant to Settlement Agreement. (Marciel, M)

1
2
3

George M. Lembo
2515 Celestial Street
Redding, CA 96002
Telephone: [phone]
[phone]
Email: [e-mail]

4
Plaintiff in Pro Se
5
6
7
8
9
10

JACKSON LEWIS LLP
CARY G. PALMER (SBN 186601)
DALE R. KUYKENDALL (SBN 148833)
JERRY J. DESCHLER, JR (SBN 215691)
801 K Street, Suite 2300
Sacramento, California 95814
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
E-mail: [e-mail]
E-mail: [e-mail]

11
Attorneys for Defendant
12
13

UNITED STATES DISTRICT COURT

14

EASTERN DISTRICT OF CALIFORNIA

15
16
17
18
19

JAMES T. CARDEN, JR., ROBERT L. FOX,
LEON W. HEDERICK, ROBERT B. KLEE,
GEORGE M. LEMBO, LOREN E. LOVELAND,
TERRY D. MYERS, CHARLES R.
SAMUELSON, MICHAEL B. SCHAFFER,
ARTHUR J. SCHUBERT, THURLOW E.
WILLIAMS, MICHELLE W. WOODS,
RAYMOND E. YOUNG, WILLIAM H.
ZIEGLER,

20
21
22

Case No. 2:09-CV-01799-WBS-CMK
STIPULATED REQUEST FOR
DISMISSAL WITH PREJUDICE AND
ORDER THEREON

Plaintiffs,
v.
CHENEGA SECURITY PROTECTION
SERVICES, LLC,

Complaint Filed:
Trial Date:

June 29, 2009
October 18, 2011

23
Defendant.
24
25

TO THE COURT AND ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

26

Pursuant to a Settlement Agreement and General Release between CHENEGA

27

SECURITY PROTECTION SERVICES, LLC and Plaintiff GEORGE LEMBO, the parties

28

hereby stipulate and request that all parties and claims be dismissed with prejudice in the above1
Stipulated Request for Dismissal With Prejudice and Order Thereon

1

entitled action. See Fed. R. Civ. P. 41(a)(1)(A)(ii) (requiring stipulation for voluntary dismissals

2

after responsive pleadings have been filed).

3
4

Dated: July 29, 2011

5

Plaintiff in Pro Se

6
7

By: /s/ George Lembo (authorized July 29, 2011)
George Lembo

Dated: July 29, 2011

JACKSON LEWIS LLP

8
By: /s/ Dale R. Kuykendall
Cary G. Palmer
Dale R. Kuykendall
Jerry J. Deschler, Jr.

9
10
11

Attorneys for Defendant
CHENEGA SECURITY PROTECTION
SERVICES, LLC

12
13
14

ORDER

15
16
17
18
19

IT IS HEREBY ORDERED that the Complaint and any and all claims for relief in the
above-referenced matter, U.S.D.C. E.D. Cal. Case No. 2:09-CV-01799-WBS-CMK, are hereby
dismissed with prejudice.
IT IS SO ORDERED.

20
21

Dated: _August 2, 2011_____________________

22
23
24
25
26
27
28
2
Stipulated Request for Dismissal With Prejudice and Order Thereon

1

PROOF OF SERVICE

2

I am employed in the County of Sacramento, State of California. I am over the age of
eighteen years and not a party to the within action; my business address is Jackson Lewis LLP,
801 K Street, Suite 2300, Sacramento, California 95814.

3
4

On August 2, 2011, I served the within:

5

STIPULATED REQUEST FOR DISMISSAL WITH PREJUDICE
AND ORDER THEREON

6
7

on the parties in said cause:

8

[ ]

by personally delivering a true and correct copy thereof to the person at the address set
forth below, in accordance with Code of Civil Procedure section 1011(a).

[✔ ]

by placing a true and correct copy thereof enclosed in a sealed envelope with postage
thereon fully prepaid for deposit in the United States Post Office mail box, at my business
address shown above, following Jackson Lewis LLP’s ordinary business practices for the
collection and processing of mail, of which I am readily familiar, and addressed as set
forth below. On the same day correspondence is placed for collection and mailing, it is
deposited in the ordinary course of business with the United States Postal Service.

[ ]

by depositing a true and correct copy thereof enclosed in a sealed envelope with delivery
fees thereon fully prepaid in a box or other facility regularly maintained by Federal
Express or delivering to an authorized courier or driver authorized by Federal Express to
receive documents, addressed as set forth below.

[ ]

by transmitting a true and correct copy by facsimile from facsimile number
[phone] to the person(s) at the facsimile number(s) set forth below, which
transmission was confirmed as complete. A copy of the transmission record is attached
hereto.

[ ]

by forwarding a true and correct copy by e-mail from e-mail address _____________ to
the person(s) at the e-mail address(es) set forth below.

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

George M. Lembo
2515 Celestial Street
Redding, CA 96002
Telephone: [phone]
Email: [e-mail]
Plaintiff in Pro Se
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct, and that this declaration was executed on August 2, 2011 at
Sacramento, California.

26
27
28

/s/ Tami J. Martinelli
Tami J. Martinelli
Proof of Service