Mitchell v. Bard Access Systems

Filing 32

STIPULATION and ORDER signed by Judge Lawrence K. Karlton on 3/22/13: This action and all claims by Plaintiff Denise Mitchell herein are dismissed with prejudice, with each party to bear their own attorneys' fees and costs. The Clerk shall close this file. (Kaminski, H)

1
2
3
4
5

HASSARD BONNINGTON LLP
THOMAS M. FRIEDER, ESQ., State Bar No. 95411
Email: [e-mail]
KENDRA J. PAPPAS, ESQ., State Bar No. 226992
Email: [e-mail]
Two Embarcadero Center, Suite 1800
San Francisco, California 94111-3941
Telephone [phone]
Fax [phone]

6
7
8
9
10
11

DAVID COONER, ESQ. (Pro Hac Vice)
Email: [e-mail]
ZANE RIESTER, ESQ. (Pro Hac Vice)
Email: [e-mail]
McCARTER & ENGLISH LLP
4 Gateway Center
11 Mulberry Street
Post Office Box 652
Newark, NJ 07102
Telephone: [phone]
Fax: [phone]

12
13
14

Attorneys for Defendant
BARD ACCESS SYSTEMS, INC.

15

UNITED STATES DISTRICT COURT

16

EASTERN DISTRICT OF CALIFORNIA

17
18
19
20
21
22

Case No. 2:11-CV-00425-LKK-CKD

DENISE MITCHELL,

JOINT STIPULATION FOR
VOLUNTARY DISMISSAL WITH
PREJUDICE OF DEFENDANT BARD
ACCESS SYSTEMS, INC. PURSUANT
TO FED. R. CIV. P. 41(a)(1)(A)(ii);
ORDER

Plaintiff,
vs.
BARD ACCESS SYSTEMS, and DOES 1
through 100,
Defendants.

23
24
25
Pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure, the
26
parties to this action, Plaintiff DENISE MITCHELL and Defendant BARD ACCESS
27
SYSTEMS, INC., by and through their respective counsel, stipulate that Plaintiff’s claims in
28

-1-

Case No. 2:11-CV-00425-LKK-CKD
STIPULATION OF PLAINTIFF’S VOLUNTARY DISMISSAL WITH PREJUDICE; [PROPOSED] ORDER

1

the above-captioned action be and hereby are dismissed with prejudice, with each party to bear

2

their own attorneys’ fees and costs.
IT IS SO STIPULATED.

3
4
5

CERTIFICATION

6
7
8

I, Thomas M. Frieder, hereby certify and affirm that the undersigned counsel,
Stewart C. Altemus and David Cooner, have authorized me to affix their electronic signatures
to this Stipulation and [Proposed] Order.

9
10
11
12

Dated: March 20, 2013

HASSARD BONNINGTON LLP
/s/ Thomas M. Frieder
Thomas M. Frieder
Attorneys for Defendant
BARD ACCESS SYSTEMS, INC.

13
14
15
16
17

Dated: March 20, 2013

18

McCARTER & ENGLISH, LLP
/s/ David Cooner
David Cooner (Pro Hac Vice)
Attorneys for Defendant
BARD ACCESS SYSTEMS, INC.

19
20
21
22

Dated:

March 20, 2013
ALTEMUS & WAGNER

23
24

/s/ Stewart C. Altemus
Stewart C. Altemus
Attorneys for Plaintiff
Denise Mitchell

25
26
27
28

-2-

Case No. 2:11-CV-00425-LKK-CKD
STIPULATION OF PLAINTIFF’S VOLUNTARY DISMISSAL WITH PREJUDICE; [PROPOSED] ORDER

1
ORDER

2
3
4
5
6
7

PURSUANT TO THE STIPULATION, IT IS HEREBY ORDERED that:
This action and all claims by Plaintiff Denise Mitchell herein are dismissed
with prejudice, with each party to bear their own attorneys’ fees and costs.
The Clerk shall close this file.
IT IS SO ORDERED.

8
9
10
11

DATED: March 22, 2013.

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

-3-

Case No. 2:11-CV-00425-LKK-CKD
STIPULATION OF PLAINTIFF’S VOLUNTARY DISMISSAL WITH PREJUDICE; [PROPOSED] ORDER