Naked Cowboy v. Brodsky

Filing 12

FILING ERROR - ELECTRONIC FILING FOR NON-ECF DOCUMENT - JOINT MOTION to Dismiss Entire Action, With Prejudice. Document filed by Sandra Brodsky, Naked Cowboy. (Barnhorst, Nicholas) Modified on 3/11/2011 (db).

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------------------- X NAKED COWBOY D/B/A NAKED COWBOY ENTERPRISES, Plaintiff, - against SANDRA BRODSKY A/K/A SANDY KANE, Defendant. --------------------------------------------------------------- X STIPULATION OF DISMISSAL WITH PREJUDICE Index No. 1:10-cv-05539-VM

Pursuant to Rule 41(a) of the Federal Rules of Civil Procedure, Plaintiff NAKED COWBOY d/b/a Naked Cowboy Enterprises and Defendant SANDRA BRODSKY a/k/a Sandy Kane hereby agree and stipulate that this action, and all claims against the Defendant and all counterclaims against the Plaintiff, be and hereby are dismissed, with prejudice, each party to bear its own costs and attorney's fees. The U.S. District Court for the Southern District of New York retains jurisdiction over this matter. Attached as Exhibit 1 hereto is a proposed order which the parties respectfully request the Court to enter.

Respectfully submitted,

s/NSB Nicholas S. Barnhorst, Esq. (NB2626) Attorney for Defendant 12 Desbrosses St. New York, NY 10013 [phone] Telephone [phone] Facsimile Dated: New York, NY, March 11, 2011

_____s/JJ/___________________ Joey Jackson, Esq. Attorney for Plaintiff Koehler & Isaacs, LLP 61 Broadway - Suite 2500 New York, NY 10006 [phone]

EXHIBIT 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------------------NAKED COWBOY D/B/A NAKED COWBOY ENTERPRISES, Plaintiff, - against SANDRA BRODSKY A/K/A SANDY KANE, Defendant. ---------------------------------------------------------------X Index No. 1:10-cv-05539-VM

STIPULATION OF DISMISSAL WITH PREJUDICE All parties to this action, having stipulated pursuant to Fed. R. Civ. P. 41 to dismissal of this action and all claims and counterclaims thereof, with prejudice, with each party to bear its own costs and attorney's fees, it is hereby ORDERED that: This action be, and hereby is, dismissed in its entirety with prejudice. The U.S. District Court for the Southern District of New York retains jurisdiction over this matter.

_________________________ Hon. Victor Marrero United States District Judge