Ingrid von Mangoldt Hills v. Intensive Air Inc.

Filing 135

ORDER GRANTING 134 Stipulation and continuing Case Management Conference to March 6, 2009.. Signed by Judge Jeffrey S. White on 1/27/09. (jjo, COURT STAFF) (Filed on 1/27/2009)

Case 3:06-cv-03300-JSW

Document 134

Filed 01/26/2009

Page 1 of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

ROBERT T. LYNCH (SB# 34716) CLAUDIA LOZANO (SB#188742) ELIA DE LUCA (SB#249059) LYNCH, GILARDI & GRUMMER 475 Sansome Street, Suite 1800 San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant/Cross-Defendant INTENSIVE AIR, INC., DBA U.S. AIR AMBULANCE

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA-SAN FRANCISCO DIVISION

INGRID VON MANGOLDT HILLS, in her individual capacity and as Representative of the Estate of REUBEN W. HILLS, III, Plaintiffs, vs. INTENSIVE AIR, INC., a corporation, doing business as U.S. AIR AMBULANCE, Defendant. _____________________________________ INTENSIVE AIR, INC., a corporation, doing business as U.S. AIR AMBULANCE, Cross-Complainant, vs. MEDICAL AIR TRANSPORT, INC., MEDICAL AIR TRANSPORT RESOURCES, JEREMY FREER and MICHAEL QUILTER, Cross-Defendants.

Case No.: C 06-3300 JSW STIPULATION AND ORDER RE: VOLUNTARY DISMISSAL OF ACTION (INCLUDING CROSSCOMPLAINTS) IN EXCHANGE FOR WAIVER OF COSTS

Case Filed: Trial Date:

5/19/06 N/A

1
STIPULATION AND ORDER RE: VOLUNTARY DISMISSAL OF ACTION (INCLUDING CROSS-COMPLAINTS) IN EXCHANGE FOR WAIVER OF COSTS

Case 3:06-cv-03300-JSW

Document 134

Filed 01/26/2009

Page 2 of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

1.

Plaintiff INGRID von MANGOLDT HILLS has agreed to voluntarily dismiss the

instant lawsuit, with prejudice against Defendant/Cross-Defendant/Cross-Claimant INTENSIVE AIR, INC. Cross-Defendant/Cross-Complainants INTENSIVE AIR, INC., MICHAEL

QUILTER, Cross-Defendant/Cross-Claimant MEDICAL AIR TRANSPORT, INC. and CrossDefendant JEREMY FREER have agreed to dismiss all cross-complaints, with prejudice, in this matter in exchange for a waiver of costs. 2. A Release and Settlement Agreement is being circulated for execution. We

anticipate that it will be fully executed within the next 30 days, upon which time we will request that dismissals, according to this stipulation be entered. 3. The parties request that the Case Management Conference currently set for

January 30, 2009 at 1:30 p.m. before the Honorable Jeffrey S. White be taken off calendar and that this matter be placed on the Court's dismissal calendar for a hearing no earlier than 30 days from the date of said stipulation. 4. Counsel stipulate that a copy of a signature transmitted by any electronic means

including, but not limited to, facsimile machine and scanned document transmitted via e-mail will have the same force and effect as an original signature. DATED: January 26, 2009 LYNCH, GILARDI & GRUMMER

By

/s/ Robert T. Lynch Claudia Lozano Attorneys for Defendant/CrossDefendant, INTENSIVE AIR, INC., DBA U.S. AIR AMBULANCE

DATED:

January 26, 2009

BREALL & BREALL, LLP By: ____/s/__________________________ Joseph M. Breall Attorney for Plaintiff INGRID VON MANGOLDT HILLS, in her individual capacity and as Representative of the Estate of REUBEN W. HILLS, III 2

STIPULATION AND ORDER RE: VOLUNTARY DISMISSAL OF ACTION (INCLUDING CROSS-COMPLAINTS) IN EXCHANGE FOR WAIVER OF COSTS

Case 3:06-cv-03300-JSW

Document 134

Filed 01/26/2009

Page 3 of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

DATED:

January 26, 2009

ROPERS, MAJESKI, KOHN & BENTLEY

By

/s/ George E. Clause Daniel McKinnon Attorneys for Cross-Defendant/CrossComplainant, MICHAEL QUILTER,

DATED:

January 26, 2009

THE WALSTON LEGAL GROUP

By

/s/ Gregory S. Walston Orestes A. Cross Attorneys for Cross-Defendant, JEREMY FREER

DATED:

January 26, 2009

LAW OFFICES OF BONNIE R. COHEN

By____/s/________________________________ Bonnie R. Cohen Attorneys for Cross-Defendant/ Cross-Complainant MEDICAL AIR TRANSPORT, INC.

3
STIPULATION AND ORDER RE: VOLUNTARY DISMISSAL OF ACTION (INCLUDING CROSS-COMPLAINTS) IN EXCHANGE FOR WAIVER OF COSTS

Case 3:06-cv-03300-JSW

Document 134

Filed 01/26/2009

Page 4 of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4
STIPULATION AND ORDER RE: VOLUNTARY DISMISSAL OF ACTION (INCLUDING CROSS-COMPLAINTS) IN EXCHANGE FOR WAIVER OF COSTS
\\Sfdata\Conversion\0010-0155\P\186383.doc

ORDER GOOD CAUSE APPEARING THEREFORE, the stipulation to remove the Case Management Conference scheduled for January 30, 2009 at 1:30 p.m. is GRANTED. An Order to Show Cause re: Dismissal will be set for hearing on ____________________ at _______ in Department ___. The parties are required to inform the Court one week prior to the OSC re: Dismissal if the execution of the Release and Settlement Agreement is complete and that Dismissal should be entered. The Court HEREBY CONTINUES the Case Management Conference scheduled for January 30, 2009 to March 6, 2009 at 1:30 p.m. The Case Management Conference shall be vacated if the parties file a stipulation of dismissal prior to March 6, 2009. DATED:__________________ January 27, 2009 ___________________________________ THE HONORABLE JEFFREY S. WHITE