V v. Kratz

Filing 13

STIPULATION Of Counsel Regarding State of Wisconsin's Motion To Intervene by All Parties.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN ________________________________________________________________________ S.V. Plaintiff, -vsCase No: 10-CV-919

KENNETH KRATZ, Defendant. ________________________________________________________________________ STIPULATION OF COUNSEL REGARDING STATE OF WISCONSIN'S MOTION TO INTERVENE ________________________________________________________________________ Plaintiff S.V. by her attorneys Fox & Fox S.C., by Michael R. Fox and defendant Kenneth Kratz by his attorneys Hammett, Bellin & Oswald, LLC, by Robert E. Bellin, Jr., and the State of Wisconsin, proposed Intervenor, by Attorney General J.B. Van Hollen by Assistant Attorneys General Monica Burkert-Brist and Carrie Benedon, stipulate as follows: 1. The parties stipulate that the State of Wisconsin's motion to intervene for

the sole purpose of litigating the issue of potential indemnification of the defendant by the State shall be granted; 2. The State stipulates that, at this stage of the proceedings, as noted in its

Motion to Intervene and supporting materials, the State wishes to be heard only on the scope of employment/indemnity issue and not on the merits or factual disputes in this case, except as may be necessary to argue the indemnity issue.

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3.

Therefore, the State stipulates that it does not, and will not seek to appear

on any issue which may be raised by defendant as to the sufficiency of the complaint filed by the plaintiff in this case. Dated: March 11, 2011 Respectfully, FOX & FOX, S.C. By: s/Michael R. Fox Michael R. Fox Attorneys for Plaintiff 124 West Broadway Monona, WI 53716 Phone: [phone] Facsimile: 608/258-9588 Email: [e-mail] HAMMETT,BELLIN & OSWALD, LLC By: s/Robert E. Bellin, Jr. Robert E. Bellin, Jr. Attorneys for Defendant 675 Deerwood Ave Neenah, WI 54956 Phone: [phone] Facsimile: 920-720-7970 E-mail: [e-mail] J.B. VAN HOLLEN Attorney General By: s/MONICA BURKERT-BRIST Assistant Attorney General State Bar #1009882 Attorneys for State of Wisconsin Wisconsin Department of Justice Post Office Box 7857 Madison, Wisconsin 53707-7857 [phone] [phone] (Fax) [e-mail]

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