J & J Sports Productions, Inc. v. Skinner et al

Filing 51

STIPULATION and ORDER signed by Judge Lawrence K. Karlton on 6/4/2014 ORDERING that Brian M. Elia, individually and d/b/a Camanche Hills Dinner House & Lounge A/K/A Bella Rosa is DISMISSED without prejudice pursuant to Federal Rules of Civil Proce dure 41(a)(1). Provided no Party has filed a motion to reopen this action by 7/31/2014, this Court shall not have jurisdiction to set aside the dismissal and the dismissal shall be deemed to be with prejudice. Each Party referenced-above shall bear its own attorneys fees and costs. This court's prior order, 50 , is WITHDRAWN. (Zignago, K.)

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Thomas P. Riley, SBN 194706
LAW OFFICES OF THOMAS P. RILEY, P.C.
First Library Square
1114 Fremont Avenue
South Pasadena, CA 91030-3227
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff
J & J Sports Productions, Inc.

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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J & J SPORTS PRODUCTIONS, INC.,
Plaintiff,

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vs.

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JOYCE ANN SKINNER, ET AL.,

CASE NO. 2:13-cv-00877-LKK-CKD
STIPULATION OF DISMISSAL OF
PLAINTIFF’S COMPLAINT AGAINST
DEFENDANT BRIAN M. ELIA, individually
and d/b/a CAMANCHE HILLS DINNER
HOUSE & LOUNGE A/K/A BELLA ROSA

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Defendants.

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IT IS HEREBY STIPULATED by and between Plaintiff J & J SPORTS PRODUCTIONS,

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INC., and Defendant BRIAN M. ELIA, individually and d/b/a CAMANCHE HILLS DINNER

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HOUSE & LOUNGE A/K/A BELLA ROSA, that the above-entitled defendant is hereby dismissed

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without prejudice against BRIAN M. ELIA, individually and d/b/a CAMANCHE HILLS DINNER

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HOUSE & LOUNGE A/K/A BELLA ROSA only.

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IT IS FURTHER STIPULATED that provided no Party referenced above has filed a motion

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to reopen this action by July 31, 2014, this Court shall not have jurisdiction to set aside the dismissal

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and the dismissal shall be deemed to be with prejudice

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STIPULATION OF DISMISSAL
Case No. 2:13-cv-00877-LKK-CKD
PAGE 1

This dismissal is made pursuant to Federal Rules of Civil Procedure 41(a)(1). Each Party

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referenced-above shall bear its own attorneys’ fees and costs.

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Dated: 5/9/14

/s/ Thomas P. Riley
LAW OFFICES OF THOMAS P. RILEY, P.C.
By: Thomas P. Riley
Attorneys for Plaintiff
J & J SPORTS PRODUCTIONS, INC.

Dated: 5/12/14

/s/ Matthew A. Pare
LAW OFFICES OF MATTHEW A. PARE, APC
By: Matthew A. Pare
Attorneys for Defendant
BRIAN M. ELIA, individually and d/b/a
CAMANCHE HILLS DINNER HOUSE & LOUNGE A/K/A
BELLA ROSA

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This court’s prior order, ECF No. 50, is WITHDRAWN, and the above stipulation is SO
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ORDERED.

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Dated: June 4, 2014.

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STIPULATION OF DISMISSAL
Case No. 2:13-cv-00877-LKK-CKD
PAGE 2

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PROOF OF SERVICE (SERVICE BY MAIL)

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I declare that:
I am employed in the County of Los Angeles, California. I am over the age of eighteen years

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and not a party to the within cause; my business address is First Library Square, 1114 Fremont Avenue,
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South Pasadena, California 91030. I am readily familiar with this law firm's practice for collection and
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processing of correspondence/documents for mail in the ordinary course of business.
On May 9, 2014, I served:
STIPULATION OF DISMISSAL OF PLAINTIFF’S COMPLAINT AGAINST
DEFENDANTS BRIAN M. ELIA, individually and d/b/a CAMANCHE HILLS DINNER
HOUSE & LOUNGE A/K/A BELLA ROSA

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On all parties referenced by enclosing a true copy thereof in a sealed envelope with postage
prepaid and following ordinary business practices, said envelope was duly mailed and addressed to:
Mr. Stephen Thomas Cammack, Esquire
STEPHEN T. CAMMACK LAW OFFICES
915 University Avenue
Sacramento, CA 95825

(Attorneys for Defendants Joyce
Ann Skinner and Larry Leroy Skinner)

Mr. Matthew A. Pare, Esquire
LAW OFFICES OF MATTHEW A. PARE, APC
823 Anchorage Place, Suite 101
Chula Vista, CA 91914

(Attorneys for Defendants Brian M.
Elia)

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The fully sealed envelope with pre-paid postage was thereafter placed in our law firm’s

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outbound mail receptacle in order that this particular piece of mail could be taken to the United States

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Post Office in South Pasadena, California later this day by myself (or by another administrative

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assistant duly employed by our law firm).

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I declare under the penalty of perjury pursuant to the laws of the United States that the

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foregoing is true and correct and that this declaration was executed on June 4, 2014, at South

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Pasadena, California.

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Dated: May 9, 2014

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VANESSA VENTURA

STIPULATION OF DISMISSAL
Case No. 2:13-cv-00877-LKK-CKD
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