Crescini v. Standard Insurance Company

Filing 16

STIPULATION AND ORDER Granting Dismissal with Prejudice of Entire Action pursuant to Federal Rule of Civil Procedure 41(a)(1)(ii) re 15 Stipulation,. The Clerk shall close this file. ***All Deadlines/Hearings terminated. Signed by Judge Edward J. Davila on 10/6/2011. (ecg, COURT STAFF) (Filed on 10/6/2011)

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WARREN H. NELSON, JR. #104744
A PROFESSIONAL CORPORATION
6161 El Cajon Boulevard, # 273
San Diego, CA 92115
Telephone: [phone]
Facsimile: [phone]
Attorney for Defendant
STANDARD INSURANCE COMPANY

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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) Case No.: CV 11-02328 EJD
)
) STIPULATION AND PROPOSED
) ORDER FOR DISMISSAL WITH
Plaintiff,
) PREJUDICE OF ENTIRE ACTION
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v.
) No hearing set or required.
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STANDARD INSURANCE
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COMPANY, et al.,
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Defendants.
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Counsel for the parties, Plaintiff Lorelei Crescini and Defendant Standard

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Insurance Company (“Standard”), jointly and respectfully submit this Stipulation

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and Order for Dismissal with Prejudice of this entire action, following settlement

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of this matter on terms that are confidential.

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LORELEI CRESCINI,

More specifically, each and all of the parties hereto, by and through their

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respective undersigned counsel, stipulate to the dismissal of this entire action with

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prejudice pursuant to Federal Rule of Civil Procedure 41(a)(1)(ii), each party to

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bear her or its own costs, expenses and attorney fees. The parties further stipulate

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that this Court shall retain continuing jurisdiction over any dispute arising out of

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STIP/ORDER TO DIMISS ENTIRE ACTION WITH PREJUDICE – CV 11-02328 EJD - 1

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the settlement of this matter. The parties add that there is no dispute currently and

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none is anticipated.

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Local Civil Rule 7-12, Stipulations, provides:

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Every stipulation requesting judicial action must be in writing signed by all

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affected parties or their counsel. A proposed form of order may be submitted

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with the stipulation and may consist of an endorsement on the stipulation of

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the words, “PURSUANT TO STIPULATION, IT IS SO ORDERED,” with

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spaces designated for the date and the signature of the Judge.

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STIP/ORDER TO DIMISS ENTIRE ACTION WITH PREJUDICE – CV 11-02328 EJD - 2

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Pursuant to their settlement and the terms of Local Rule 7-12, the parties

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respectfully request that the Court enter the Order that follows.

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So Stipulated:

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Dated: September 29, 2011

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Attorneys for Plaintiff
LORELEI CRESCINI

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Dated: September 29, 2011

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s/Warren H. Nelson, Jr.
WARREN H. NELSON, JR. 104744
A PROFESSIONAL CORPORATION
6161 El Cajon Boulevard, # 273
San Diego, CA 92115
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

Attorney for Defendant
STANDARD INSURANCE COMPANY
SIGNATURE ATTESTATION

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s/Constantin V. Roboostoff
CONSTANTIN V. ROBOOSTOFF 69328
ROBOOSTOFF & KALKIN
A PROFESSIONAL LAW
CORPORATION
369 Pine Street, Suite 820
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

Pursuant to General Order No. 45 § XB, I, Warren H. Nelson, Jr., the e filer

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of this document, attest that concurrence in the filing of this document has been

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obtained from the other signatory shown above, Constantin V. Roboostoff, Esq,

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who is a registered “e filer” with this Court.

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Dated: September 29, 2011

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s/Warren H. Nelson, Jr.
WARREN H. NELSON, JR. # 104744
PURSUANT TO STIPULATION, IT IS SO ORDERED. The Clerk shall close this file.

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Dated: October __, 2011
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_____________________________
EDWARD J. DAVILA, JUDGE
UNITED STATES DISTRICT COURT

STIP/ORDER TO DIMISS ENTIRE ACTION WITH PREJUDICE – CV 11-02328 EJD - 3