The Michel Family Trust v. Travelers Indemnity Company of Conneticut et al

Filing 31

STIPULATION AND ORDER TO DISMISS PLAINTIFF'S CLAIMS FOR BREACH OF THE COVENANT OF GOOD FAITH AND FAIR DEALING, NEGLIGENCE AND PUNITIVE DAMAGES WITH PREJUDICE. Signed by Judge Patricia V. Trumbull on August 23, 2010. (pvtlc2, COURT STAFF) (Filed on 8/23/2010)

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The Michel Family Trust v. Travelers Indemnity Company of Conneticut et al Doc. 31 1 2 3 4 5 6 7 8 FORAN GLENNON PALANDECH PONZI & RUDLOFF PC MARJIE D. BARROWS (SBN 122129) KATHLEEN M. DELANEY (SBN 196376) FORAN GLENNON PALANDECH PONZI & RUDLOFF PC 2000 Powell Street, Suite 900 Emeryville, CA 94608 Telephone: (510) 740-1500 Facsimile: (510) 740-1501 E-mail: mbarrows@fgppr.com kdelaney@fgppr.com Attorneys for Defendant TRAVELERS INDEMNITY COMPANY OF CONNECTICUT UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 9 10 11 ATTORNEYS AT LAW 2000 POWELL STREET, SUITE 900 EMERYVILLE, CALIFORNIA 94608 (510) 740-1500 THE MICHEL FAMILY TRUST, Plaintiff, vs. TRAVELERS INDEMNITY COMPANY OF CONNECTICUT, THE TRAVELERS INDEMNITY COMPANY, and DOES 1 to 100, inclusive, Defendants. CASE NO. C09-04144 PVT STIPULATION TO DISMISS PLAINTIFF'S CLAIMS FOR BREACH OF THE COVENANT OF GOOD FAITH AND FAIR DEALING, NEGLIGENCE AND PUNITIVE DAMAGES WITH PREJUDICE; [PROPOSED] ORDER THEREON 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TO THE HONORABLE PATRICIA V. TRUMBULL, U.S. DISTRICT COURT MAGISTRATE JUDGE: STIPULATION WHEREAS, Plaintiff MICHEL FAMILY TRUST has agreed to dismiss its claims against Defendant THE TRAVELERS INDEMNITY COMPANY OF CONNECTICUT for Breach of the Covenant of Good Faith and Fair Dealing, Negligence and Punitive Damages, with prejudice, under Federal Rules of Civil Procedure, Rule 41(a)(2); and The parties to this action agree, through their respective attorneys, that Plaintiff MICHEL FAMILY TRUST hereby dismisses its claims against Defendant THE TRAVELERS -1STIP. AND ORDER TO DISMISS BAD FAITH, NEGLIGENCE AND PUNITIVE DAMAGES CASE NO. C09-04144 PVT Dockets.Justia.com 1 2 3 4 5 6 7 8 FORAN GLENNON PALANDECH PONZI & RUDLOFF PC INDEMNITY COMPANY OF CONNECTICUT for Breach of the Covenant of Good Faith and Fair Dealing, Negligence and Punitive Damages, with prejudice, IT IS SO STIPULATED. Respectfully submitted, DATED: August 20, 2010 FORAN GLENNON PALANDECH PONZI & RUDLOFF PC By: __/s/ Kathleen M. DeLaney Kathleen M. DeLaney __________ 9 10 11 ATTORNEYS AT LAW 2000 POWELL STREET, SUITE 900 EMERYVILLE, CALIFORNIA 94608 (510) 740-1500 Attorneys for Defendant TRAVELERS INDEMNITY COMPANY OF CONNECTICUT 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2STIP. AND ORDER TO DISMISS BAD FAITH, NEGLIGENCE AND PUNITIVE DAMAGES CASE NO. C09-04144 PVT ORDER OF DISMISSAL Based on the above-stated stipulation, and good cause otherwise appearing, IT IS ORDERED that Plaintiff's claims against Defendant THE TRAVELERS INDEMNITY COMPANY OF CONNECTICUT for Breach of the Covenant of Good Faith and Fair Dealing, Negligence and Punitive Damages are hereby dismissed, with prejudice. Date: August 23, 2010 DATED: August 20, 2010 WILLIAMS, PINELLI & CULLEN, LLP By: __/s/ Amy Carlson Amy Carlson Attorneys for Plaintiff MICHEL FAMILY TRUST __________ _________________________________ PATRICIA V. TRUMBULL UNITED STATES MAGISTRATE JUDGE

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