Martinez, et al., v. SCC Florin Road Bingo, et al.,

Filing 50

STIPULATION and ORDER signed by Magistrate Judge Gregory G. Hollows on 12/12/11: Plaintiffs' Complaint shall be dismissed with prejudice as against all remaining defendants. The Court will retain jurisdiction to enforce the Consent Decree and Order entered by the Court on August 29, 2011 48 .The Clerk shall close this case.(Kaminski, H)

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PAUL L. REIN, Esq. (SBN 43053)
CELIA MCGUINNESS, Esq. (SBN 159420)
CATHERINE M. CABALO, Esq. (SBN 248198)
LAW OFFICES OF PAUL L. REIN
200 Lakeside Drive, Suite A
Oakland, CA 94612
Telephone: [phone]
Facsimile: 510/832-4787
[e-mail]

Attorneys for Plaintiffs
CONNIE MARTINEZ and
7 JOSE MARTINEZ
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*Defendants and their respective are counsel listed after the caption.

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IN THE UNITED STATES DISTRICT COURT

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IN AND FOR THE EASTERN DISTRICT OF CALIFORNIA

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CONNIE MARTINEZ and
JOSE MARTINEZ,

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Case No. 2:10-cv-01647 GEB-GGH
Civil Rights

Plaintiffs,
v.

STIPULATION AND ORDER
FOR DISMISSAL OF CLAIMS
AGAINST DEFENDANTS SCC
FLORIN ROAD BINGO,
SACRAMENTO
CONSOLIDATED CHARITIES,
KEVIN BEERS, AND SHAW
MARTINEZ WITH PREJUDICE

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SCC FLORIN ROAD BINGO;
16 SACRAMENTO
CONSOLIDATED CHARITIES;
17 KEVIN BEERS; SHAWN
MARTINEZ; ARC PROPERTIES,
18 INC.; AND DOES 1-10,
INCLUSIVE,
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Defendants.

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/

SCOTT E. COFER, Esq.
GREVE, CLIFFORD, WENGEL & PARAS, LLP
22 2870 Gateway Oaks Drive, Suite 210
Sacramento, CA 95833
23 Telephone: [phone]
Facsimile: 916/441-7457
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Attorneys for Defendants
25 SCC FLORIN ROAD BINGO, SACRAMENTO
CONSOLIDATED CHARITIES, KEVIN BEERS,
26 AND SHAW MARTINEZ (erroneously sued as
SHAWN MARTINEZ)
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STIPULATION AND PROPOSED ORDER
OF DISMISSAL OF ALL CLAIMS AGAINST
ALL REMAINING DEFENDANTS
Case No. 2:10-cv-01647 GEB-GGH
G:\DOCS\GGH\DGGH1\signed - ggh\Martinez1647.docx

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STIPULATION

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Pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure,

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plaintiffs CONNIE AND JOSE MARTINEZ (“Plaintiffs”) and defendants SCC

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FLORIN ROAD BINGO, SACRAMENTO CONSOLIDATED CHARITIES,

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KEVIN BEERS, and SHAW MARTINEZ (erroneously sued as SHAWN

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MARTINEZ) (together referred to as “Defendants”), by and through their respective

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attorneys of record, stipulate that:

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1.

Plaintiffs’ Complaint in the above-entitled action shall be dismissed

with prejudice as against Defendants;
2.

The Court will retain jurisdiction to enforce the Consent Decree and

Order entered by the Court on August 29, 2011 (see Docket No. 48); and
IT IS SO STIPULATED.
Dated: November 29, 2011

LAW OFFICES OF PAUL L. REIN

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/s/ Catherine M. Cabalo
By: Catherine M. Cabalo, Esq.
Attorneys for Plaintiffs
CONNIE AND JOSE MARTINEZ

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Dated: November 29, 2011

GREVE, CLIFFORD, WENGEL &
PARAS, LLP

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/Scott E. Cofer/
By: Scott E. Cofer, Esq.
Attorneys for Defendants
SCC FLORIN ROAD BINGO,
SACRAMENTO CONSOLIDATED
CHARITIES, KEVIN BEERS, AND
SHAW MARTINEZ
(ERRONEOUSLY SUED AS
SHAWN MARTINEZ)

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-2STIPULATION AND PROPOSED ORDER
OF DISMISSAL OF ALL CLAIMS AGAINST
ALL REMAINING DEFENDANTS
Case No. 2:10-cv-01647 GEB-GGH
G:\DOCS\GGH\DGGH1\signed - ggh\Martinez1647.docx

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ORDER

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Having reviewed the above Stipulation for Dismissal of Claims against

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Defendants SCC FLORIN ROAD BINGO, SACRAMENTO CONSOLIDATED

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CHARITIES, KEVIN BEERS, and SHAW MARTINEZ (erroneously sued as

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SHAWN MARTINEZ) with Prejudice submitted by plaintiffs CONNIE AND JOSE

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MARTINEZ (“Plaintiffs”) on the one hand and Defendants SCC FLORIN ROAD

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BINGO, SACRAMENTO CONSOLIDATED CHARITIES, KEVIN BEERS, and

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SHAW MARTINEZ (erroneously sued as SHAWN MARTINEZ) on the other

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hand,

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IT IS HEREBY ORDERED that:

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1.

Plaintiffs’ Complaint in the above-entitled action shall be dismissed

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with prejudice as against all remaining defendants SCC FLORIN ROAD BINGO,

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SACRAMENTO CONSOLIDATED CHARITIES, KEVIN BEERS, and SHAW

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MARTINEZ (erroneously sued as SHAWN MARTINEZ);

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2.

The Court will retain jurisdiction to enforce the Consent Decree and

Order entered by the Court on August 29, 2011 (see Docket No. 48).
3.

The Clerk shall close this case.

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Dated: December 12, 2011

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/s/ Gregory G. Hollows
__________________________________
Honorable GREGORY G. HOLLOWS
United States Magistrate Judge

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-3STIPULATION AND PROPOSED ORDER
OF DISMISSAL OF ALL CLAIMS AGAINST
ALL REMAINING DEFENDANTS
Case No. 2:10-cv-01647 GEB-GGH
G:\DOCS\GGH\DGGH1\signed - ggh\Martinez1647.docx