Trader v. United States et al

Filing 53

ORDER: Granting Stipulated Motion for Limited Judgment of Dismissal 52 . Signed on 10/17/2017 by Judge Michael J. McShane. (cp)

Robert E. Barton, OSB No. 814637
Internet e-mail: rbarton©cosgravelaw.com
COSGRAVE VERGEER KESTER LLP
888 SW Fifth Avenue, Suite 500
Portland, Oregon 97204
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Defendants Security Guys,
LLC and Security Guys, Inc.
UNITED STATES DISTRICT COURT
DISTRICT OF OREGON
MEDFORD DIVISION
THE ESTATE OF JESSE AUSTIN
TRADER, by and through TED L. TRADER,
Personal Representative for The Estate of
Jesse Austin Trader,
Plaintiff,

Case No. 1:16-CV-01385-MC
STIPULATED LIMITED
JUDGMENT OF DISMISSAL WITH
PREJUDICE AS TO DEFENDANTS
SECURITY GUYS, LLC AND
SECURITY GUYS, INC.

v.
UNITED STATES, acting through its
agencies, the United States Department of
Transportation; USDA Forest Service.
Bureau of Land Management - Washington
DC; Bureau of Land Management - Oregon;
and the Northwest Interagency Coordination
Center,
Defendants,
and
DUTCH MINING, L.L.C., an Oregon
Domestic Limited Liability Company,
Defendant,
and
SECURITY GUYS, LLC, an Oregon
Domestic Limited Liability Company; and
SECURITY GUYS, INC., an Oregon
Domestic Business Corporation,
Defendants,
Page 1 -

STIPULATED LIMITED JUDGMENT OF DISMISSAL
WITH PREJUDICE AS TO DEFENDANTS SECURITY GUYS, LLC AND
SECURITY GUYS, INC.
Cosgrave Verge.. Koster LLP
Attorneys
888 SW Fifth Avenue, Suite 500
Portland, Oregon 97204
Telephone: [phone] Facsimile: [phone]

and
DANIEL TRADER, an individual,
Defendant.

IT IS HEREBY STIPULATED that plaintiff's claims against defendants Security
Guys, LLC and Security Guys, Inc. have been fully compromised and settled and shall
be dismissed with prejudice and without attorney fees or costs to any party.
IT IS SO STIPULATED:
Dated:

9-21-17

Dated:
Ro•ert E. Barton, OSB No. 814637
Attorney for Defendants Security Guys,
LLC and Security Guys, Inc.
Based on the parties' stipulation, it is
ADJUDGED that plaintiff's claims against defendants Security Guys, LLC and
Security Guys, Inc. are dismissed with prejudice and without costs to any party.
DATED this 17th day of

October

, 2017.

s/Michael J. McShane
United States District Court
Judge Michael J. McShane

Page 2 -

STIPULATED LIMITED JUDGMENT OF DISMISSAL
WITH PREJUDICE AS TO DEFENDANTS SECURITY GUYS, LLC AND
SECURITY GUYS, INC.
Cosgrove Vorg per )(ester LLP
Attemays
588 SW Fifth Avenue, Suite 500
Portland, Oregon 97204
"Foie phone: [phone] Facsimile: [phone]

CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of the foregoing
[PROPOSED] STIPULATED LIMITED JUDGMENT OF DISMISSAL WITH
PREJUDICE AS TO DEFENDANTS SECURITY GUYS, LLC AND SECURITY GUYS,
INC. on the date indicated below by:
u

mail with postage prepaid, deposited in the US mail at Portland, Oregon,

u

hand delivery,

u

facsimile transmission,

u

overnight delivery,
electronic filing notification.

If served by facsimile transmission, attached to this certificate is the printed
confirmation of receipt of the document(s) generated by the transmitting machine. I
further certify that said copy was placed in a sealed envelope delivered as indicated
above and addressed to said attorney(s) at the address(es) listed below:
Robert L. Winkler
Jeremy C. Rice
Parks Bauer Sime Winkler & Fernety LLP
200 Civic Center Office Building
570 Liberty St. SE
Salem, OR 97301
Of Attorneys for Plaintiff
Carl R. Amala
Harris Wyatt & Amala
5778 Commercial Street, SE
Salem, OR 97306
Of Attorneys for Plaintiff
Billy J. Williams
United States Attorney
Kevin Danielson
Assistant United States Attorney
1000 SW 3 rd, Suite 600
Portland, OR 97204-2902
Of Attorneys for the United States
Page 1 - CERTIFICATE OF SERVICE
Cosgrove Vorgeer Kesler LLP
Attorneys
888 SW Fifth Avenue, Suite 500
Portland, Orogen 97204
Telephom [phone] Facsimile: 1803) 321.9019

Bernard S. Moore
Frohnmayer Deatherage Jamieson
Moore Armosino & McGovern PC
2592 East Barnette Road
Medford, OR 97504
Of Attorneys for Defendant Dan Trader

2017

DATED:

Robert E. Barton

Page 1 - CERTIFICATE OF SERVICE
Attorneys
Age SIN Fifth Men., Sane SCA
Portland, Oregon 97204
Telephone: [phone] Facsimile: 003) 323-9010