Incentive Capital v. Camelot Entertainment Group et al

Filing 124

STIPULATED MOTION to Dismiss and Proposed Order Granting Dismissal with Prejudice by Incentive Capital. (Pia, Joseph) Modified on 11/16/2011 ; changed event from Stipulation to Stipulated Motion (asp).

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Joseph G. Pia (9945) Nathan S. Dorius (8977) PIA ANDERSON DORIUS REYNARD & MOSS, PLLC Wells Fargo Building 222 South Main Street, Suite 1800 Salt Lake City, Utah 84101 Tel: (801) 350-9000 Fax: (801) 350-9010 Email: Attorneys for Plaintiff Incentive Capital, LLC ______________________________________________________________________________ IN THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH, CENTRAL DIVISION INCENTIVE CAPITAL, LLC, a Utah Limited Liability Company, Plaintiff, v. CAMELOT ENTERTAINMENT GROUP, INC., a Delaware Corporation; CAMELOT FILM GROUP, INC., a Nevada Corporation; CAMELOT DISTRIBUTION GROUP, INC., a Nevada Corporation, ROBERT P. ATWELL, an individual; JAMIE R. THOMPSON, an individual; STEVEN ISTOCK, an individual; TED BAER, an individual; PETER JAROWEY, an individual, STIPULATION OF DISMISSAL AND [PROPOSED] ORDER GRANTING DISMISSAL WITH PREJUDICE Defendants. ******* Civil No.: 2:11-CV-00288 Judge Clark Waddoups The undersigned, for and on behalf of the above named Plaintiff and Defendants, hereby stipulate and agree to the dismissal, with prejudice, of all claims, with the parties to bear their own costs and attorneys fees. Filed concurrently herewith is an Application for Writ of Execution and a Writ of Execution that shall survive the dismissal of this case and have full force and effect on the parties. DATED this 16th day of November, 2011. PIA, ANDERSON, DORIUS, REYNARD & MOSS By: /s/ Joseph Pia Joseph Pia Attorneys for Plaintiff Incentive Capital, LLC KASOWITZ, BENSON, TORRES & FRIEDMAN LLP By: /s/ David J. Shapiro David J. Shapiro Attorneys for Defendant Peter Jarowey LEVITAN LAW OFFICES MORGAN MINNOCK RICE & JAMES By: /s/ Jonathan Levitan By: /s/ Dennis R. James Attorney for Defendant Ted Baer VAN COTT BAGLEY CORNALL & McCARTHY By: /s/ John Snow Attorneys for Defendants Camelot Entertainment Group, Inc., Camelot Film Group, Inc., Camelot Distribution Group Inc., Robert P. Atwell, Jamie R. Thompson, Steven Istock, Ted Baer IT IS HEREBY ORDERED that the above-captioned action is dismissed with prejudice in its entirety as against all parties. DATED this _____ day of ___________________, 2011. BY THE COURT: ________________________ Honorable Clark Waddoups United States District Court

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