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).

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: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]
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