Stockwire Research Group, Inc. et al v. Lebed et al

Filing 76

STIPULATION of Dismissal and Motion for Final Order of Dismissal as to Defendant Constance Lebed by Constance Lebed, Stockwire Research Group, Inc., Adrian James. (Koziol, Peter)

Stockwire Research Group, Inc. et al v. Lebed et al

Doc. 76

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No.: 07-22670 CIV-SEITZ/O'SULLIVAN STOCKWIRE RESEARCH GROUP, INC. a Florida corporation, and ADRIAN JAMES, a Texas Resident. Plaintiffs, vs. JONATHAN LEBED, a Florida resident, LEBED BIZ, L.L.C., a New Jersey Limited Liability Company, PIGASA, INC., a New Jersey Corporation, and CONSTANCE LEBED, a New Jersey Resident. Defendants. __________________________________________/ JOINT STIPULATION AND MOTION FOR FINAL ORDER OF DISMISSAL AS TO DEFENDANT CONSTANCE LEBED It is hereby stipulated and agreed that Plaintiff Stockwire Research Group, Inc., Plaintiff Adrian James, and Defendant Constance Lebed hereby agree that this action be dismissed with prejudice as to Constance Lebed personally. Stockwire Research Group, Inc. and Constance Lebed to bear their respective costs, including any possible attorneys' fees, costs, or other expenses of this litigation, and jointly move this Court to enter a final Order of Dismissal with Prejudice as to Constance Lebed only.1 DATED: July 2, 2008 [Electronic signature page follows]

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This in no way should be construed as a waiver by Stockwire Research Group, Inc. of its right to seek attorneys' fees and costs from the other Defendants, Jonathan Lebed, Lebed Biz, LLC and Pigasa, Inc.

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Stockwire Research Group, Inc. v. Lebed, et. al. Case No.: 07-22670 CIV-SEITZ/O'SULLIVAN

Respectfully submitted, FOWLER WHITE BURNETT, P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131-3302 Telephone: [phone] Facsimile: [phone] By: By: s/Susan H. Aprill Susan H. Aprill (FBN: 346934) [e-mail] Attorneys for the Defendant Constance Lebed

Respectfully submitted, ASSOULINE & BERLOWE, P.A. 3250 Mary Street Suite, 308 Miami, Florida 33133 Telephone: [phone] Facsimile: 305-567-9343 s/Peter A. Koziol Peter E. Berlowe (FBN 143650) [e-mail] Peter A. Koziol (FBN 0030446) [e-mail] Attorneys for Adrian James, and Stockwire Research Group, Inc.

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Stockwire Research Group, Inc. v. Lebed, et. al. Case No.: 07-22670 CIV-SEITZ/O'SULLIVAN

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served via the methods referenced below this day July 2, 2008 on all counsel or parties of record on the service list indicated below: SERVICE LIST Stockwire Research Group, Inc. v. Lebed, et. al. CASE NO.: 07-22670 CIV-SEITZ/O'SULLIVAN United States District Court, Southern District of Florida U.S. Mail Defendant Jonathan Lebed [e-mail] 49 Ivy Place Wayne, New Jersey 07470 Telephone No.: [phone] Defendant Lebed Biz, LLC c/o Jonathan Lebed 49 Ivy Place, Wayne, New Jersey 07470 Telephone No.: [phone] Defendant Pigasa, Inc.2 c/o Jonathan Lebed, Registered Agent 26 Sunset Terrace Cedar Grove, NJ 07009 Telephone No.: [phone] CM/ECF SUSAN H. APRILL, ESQ. (FBN: 346934) [e-mail] Fowler White Burnett, P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131-3302 Telephone: [phone] Facsimile: [phone] Attorneys for the Defendant Constance Lebed

By:

s/Peter A. Koziol Peter A. Koziol

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Constance Lebed objects to this as the service address for Pigasa, Inc., so an additional service for this Joint Stipulation and Motion for Final Order of Dismissal as to Constance Lebed will also be served on Pigasa, Inc. c/o Jonathan Lebed at 49 Ivy Place Wayne, New Jersey 07470.

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