Parks v. Kindred Healthcare, Inc. et al

Filing 38

STIPULATION TO DISMISS THE ENTIRE ACTION WITH PREJUDICE [FED. R. CIV. PRO. 41(A)] AND ORDER. Signed by Judge Saundra Brown Armstrong on 2/23/16. (jebS, COURT STAFF) (Filed on 2/23/2016)

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LAW OFFICES OF RANDAL M. BARNUM
Randal M. Barnum, Bar No. 111287
[e-mail]
Carrie E. Croxall, Bar No. 190430
[e-mail]
Lindsay R. Batcha, Bar No. 264192
[e-mail]
279 East H Street
Benicia, California 94510
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Plaintiff
Karen A. Parks

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SHAW VALENZA LLP
D. Gregory Valenza, Bar No. 161250
[e-mail]
980 Ninth Street, Suite 2300
Sacramento, California 95814
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendants
Kindred Healthcare, Inc., erroneously sued as
Kindred Healthcare Incorporated, and Professional
HealthCare at Home, LLC

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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KAREN A. PARKS, an individual,

Case No. 4:15-cv-01788-SBA

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Plaintiff,
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v.
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STIPULATION TO DISMISS THE
ENTIRE ACTION WITH PREJUDICE
[FED. R. CIV. PRO. 41(A)]; [PROPOSED]
ORDER

KINDRED HEALTHCARE
INCORPORATED, PROFESSIONAL
HEALTHCARE at HOME, LLC, and Does
1-100, inclusive,
Defendants.

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S HAW V ALENZA LLP
ATTORNEYS AT LAW
SACRAMENTO

STIPULATION TO DISMISS ENTIRE ACTION; [PROPOSED] ORDER

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IT IS HEREBY STIPULATED by and between the parties to this action through their

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designated counsel that the above-captioned action be and hereby is dismissed with prejudice

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pursuant to Fed. R. Civ. Pro. 41(a), each side to bear his or its own costs and attorney’s fees.

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SO STIPULATED.

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Dated: February 23, 2016

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Respectfully submitted,
LAW OFFICES OF RANDAL M. BARNUM

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By: /s/Randal M. Barnum
Randal M. Barnum
Carrie E. Croxall
Lindsay R. Batcha
Attorneys for Plaintiff
Karen A. Parks

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Dated: February 23, 2016

Respectfully submitted,
SHAW VALENZA LLP

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By: /s/D. Gregory Valenza
D. Gregory Valenza
Attorneys for Defendants
Kindred Healthcare, Inc., and Professional
HealthCare at Home, LLC

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S HAW V ALENZA LLP
ATTORNEYS AT LAW
SACRAMENTO

-2STIPULATION TO DISMISS ENTIRE ACTION; [PROPOSED] ORDER

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Filer’s Attestation
Pursuant to Civil Local Rules, rule 5-1(i)(3), I attest under penalty of perjury that
concurrence in the filing of the document has been obtained from its signatory.

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Dated: February 23, 2016

By: /s/D. Gregory Valenza

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Certificate of Service
I hereby certify that this document(s) filed through the ECF system will be sent
electronically to the registered participants as identified on the Notice of Electronic Filing

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(NEF) and paper copies will be sent to those indicated as non-registered participants on

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February 23, 2016.

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Dated: February 23, 2016

By: /s/D. Gregory Valenza

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S HAW V ALENZA LLP
ATTORNEYS AT LAW
SACRAMENTO

-3STIPULATION TO DISMISS ENTIRE ACTION; [PROPOSED] ORDER

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION,

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IT IS HEREBY ORDERED that the above entitled action and Plaintiff Karen A. Parks’

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First Amended Complaint in this matter are dismissed in its entirety with prejudice pursuant to

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Fed. R. Civ. Pro. 41(a).

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IT IS FURTHER ORDERED that each party shall bear her or its own costs and attorney’s
fees.

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DATED: February 23, 2016

__________________________________
United States District Judge
Saundra Brown Armstrong

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438021.2.00133.117

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S HAW V ALENZA LLP
ATTORNEYS AT LAW
SACRAMENTO

-4STIPULATION TO DISMISS ENTIRE ACTION; [PROPOSED] ORDER