Raymond v. Unum Life Insurance Company of America

Filing 36

STIPULATION AND ORDER TO DISMISS ENTIRE ACTION WITH PREJUDICE. Signed by Judge Richard Seeborg on 7/11/19. (cl, COURT STAFF) (Filed on 7/11/2019)

1 James P. Keenley (Bar No. 253106)
[e-mail]
2 Brian H. Kim (Bar No. 215492)
[e-mail]
3 BOLT KEENLEY KIM LLP
2855 Telegraph Ave., Suite 517
4 Berkeley, CA 94705
Telephone: [phone]
5 Facsimile: [phone]
6 Attorneys for Plaintiff
BARBARA RAYMOND
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Anna Maria Martin (Bar No. 154279)
8 [e-mail]
Grant E. Ingram (Bar No. 242785)
9 [e-mail]
MESERVE, MUMPER & HUGHES LLP
10 1000 Wilshire Boulevard, Suite 1860
Los Angeles, California 90017
11 Telephone: [phone]
Facsimile: [phone]
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Attorneys for Defendant
13 UNUM LIFE INSURANCE COMPANY OF AMERICA
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO)
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BARBARA RAYMOND,
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Plaintiff,
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vs.
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UNUM LIFE INSURANCE COMPANY OF
21 AMERICA,
Defendant.

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Case No. 3:18-cv-02272-RS
JOINT STIPULATION TO DISMISS
ENTIRE ACTION WITH
PREJUDICE; ORDER THEREON
Complaint Filed:

April 16, 2018

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IT IS HEREBY STIPULATED, by and between Plaintiff BARBARA RAYMOND and

25 Defendant UNUM LIFE INSURANCE COMPANY OF AMERICA, (collectively, the “Parties”)
26 by and through their respective attorneys of record, that this action shall be dismissed in its entirety
27 with prejudice as to all defendants pursuant to Rule 41(a) of the Federal Rules of Civil Procedure.
28 Each Party shall bear its own attorneys’ fees and costs.

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170442.1

Case No. 3:18-cv-02272-RS
JT. STIP. TO DISMISS ENTIRE ACTION WITH
PREJUDICE; [PROPOSED] ORDER THEREON

The Parties further stipulate and request that all dates set in this matter be vacated and taken

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2 off the Court’s calendar.
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The Parties seek the Court’s approval of the dismissal of the action with prejudice.

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IT IS SO STIPULATED.

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Dated: July 11, 2019

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BOLT KEENLEY KIM LLP
Brian H. Kim
James P. Keenley

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By: /s/ James P. Keenley
James P. Keenley
Attorneys for Plaintiff
BARBARA RAYMOND

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Dated: July 11, 2019

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MESERVE, MUMPER & HUGHES LLP
Anna Maria Martin
Grant E. Ingram

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By: /s/ Anna Maria Martin
Anna Maria Martin
Attorneys for Defendant
UNUM LIFE INSURANCE COMPANY
OF AMERICA

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FILER’S ATTESTATION

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The filing attorney attests that she has obtained concurrence regarding the filing of this

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21 document and its content from the signatories to this document.
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170442.1

Case No. 3:18-cv-02272-RS
JT. STIP. TO DISMISS ENTIRE ACTION WITH
PREJUDICE; [PROPOSED] ORDER THEREON

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ORDER

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Based upon the Stipulation of the Parties and for good cause shown, IT IS HEREBY

3 ORDERED that this action, Case No. 3:18-cv-02272-RS, is dismissed in its entirety as to all
4 defendants, with prejudice.
IT IS HEREBY FURTHER ORDERED that all dates previously set in this matter are

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6 hereby vacated and taken off the Court’s calendar.
IT IS HEREBY FURTHER ORDERED that each Party shall bear its own attorneys’ fees

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8 and costs in this matter.
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IT IS SO ORDERED
July 11, 2019
Dated: ___________________
Hon. Richard Seeborg
United States District Court Judge

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170442.1

Case No. 3:18-cv-02272-RS
JT. STIP. TO DISMISS ENTIRE ACTION WITH
PREJUDICE; [PROPOSED] ORDER THEREON