Bramscum v. San Ramon Police Department et al

Filing 89

STIPULATION AND ORDER DISMISSING ENTIRE ACTION WITHOUT PREJUDICE PER FRCP 41(a)(2). Signed by Magistrate Judge Laurel Beeler on 2/4/2016. (lsS, COURT STAFF) (Filed on 2/4/2016)

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JAMES V. FITZGERALD, III (State Bar No. 55632)
NOAH G. BLECHMAN (State Bar No. 197167)
MCNAMARA, NEY, BEATTY, SLATTERY,
BORGES & AMBACHER LLP
1211 Newell Avenue
Post Office Box 5288
Walnut Creek, CA 94596
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
SAN RAMON POLICE DEPARTMENT, CHIEF SCOTT
HOLDER, CITY OF SAN RAMON, OFFICER PAUL BURKE,
OFFICER JOSEPH NUNN, OFFICER T J REEDER, OFFICER
JONATHAN STEPHENS and OFFICER STANLEY SZETO

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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JORDAN EDWARD BRANSCUM,

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Case No. C11-04137 LB

Plaintiff,

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STIPULATION AND [PROPOSED]
ORDER TO DISMISS ENTIRE ACTION,
WITH PREJUDICE PER FRCP 41(a)(2)

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SAN RAMON POLICE DEPARTMENT et
al.

Judge:

Hon. Laurel Beeler

Defendants.

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The parties, by and through their respective attorneys of record, hereby stipulate and

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jointly request an Order from the Court to a dismissal of this entire action, with prejudice, in

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light of settlement of this action.

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WHEREAS, Plaintiff hereby agrees to voluntarily dismiss, with prejudice, all of his

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claims for damages against Defendants, as against all Defendants, as alleged in Plaintiffs First

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Amended Complaint, filed in this matter. This dismissal would be a dismissal for the entire

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action, against all parties, with prejudice.

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WHEREAS, each party agrees to bear its own fees and costs as to this dismissal.

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STIPULATION AND ORDER TO DISMISS ENTIRE ACTION
WITH PREJUDICE- Cll-04137 LB

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The parties attest that concurrence in the filing of these documents has been obtained from
each of the other Signatories, which shall serve in lieu of their signatures on the document.
SO STIPULATED.

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Dated: February 3, 2016

LAW OFFICES OF PANOS LAGOS

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By:

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Dated: February 3, 2016

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/s/ Lagos, Panos
Panos Lagos, Esq.
Attorney for Plaintiff,
JORDAN EDWARD BRANSCUM

MCNAMARA, NEY, BEATTY, SLATTERY,
BORGES & AM BACHER LLP

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/s/ Blechman. Noah
James V. Fitzgerald, III I Noah G. Blechman
Attorneys for Defendants
SAN RAMON POLICE DEPARTMENT, CHIEF
SCOTT HOLDER, CITY OF SAN RAMON,
OFFICER PAUL BURKE, OFFICER JOSEPH NUNN,
OFFICER T J REEDER, OFFICER JONATHAN
STEPHENS and OFFICER STANLEY SZETO

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ORDER
PURSUANT TO STIPULATION AND REQUEST, IT IS ORDERED AS FOLLOWS:
The Court hereby dismisses this entire action, as to all claims and Defendants, with
prejudice. Each party bears its own fees and costs as to this dismissal.
IT IS SO ORDERED

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February 4
Dated: _ _ _ _ _ , 2016

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Hon. Laurel Beeler
United States Magistrate Judge

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STIPULATION AND ORDER TO DISMISS ENTIRE ACTION
WITH PREJUDICE- CI 1-04137 LB

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