Opinion
Case No.: CV 11-02328 EJD
10-06-2011
LORELEI CRESCINI, Plaintiff, v. STANDARD INSURANCE COMPANY, et al., Defendants.
CONSTANTIN V. ROBOOSTOFF 69328 ROBOOSTOFF & KALKIN A PROFESSIONAL LAW CORPORATION Attorneys for Plaintiff LORELEI CRESCINI Attorney for Defendant STANDARD INSURANCE COMPANY
WARREN H. NELSON, JR. #104744
A PROFESSIONAL CORPORATION
Attorney for Defendant
STANDARD INSURANCE COMPANY
STIPULATION AND PROPOSED
ORDER FOR DISMISSAL WITH
PREJUDICE OF ENTIRE ACTION
No hearing set or required.
Counsel for the parties, Plaintiff Lorelei Crescini and Defendant Standard Insurance Company ("Standard"), jointly and respectfully submit this Stipulation and Order for Dismissal with Prejudice of this entire action, following settlement of this matter on terms that are confidential.
More specifically, each and all of the parties hereto, by and through their respective undersigned counsel, stipulate to the dismissal of this entire action with prejudice pursuant to Federal Rule of Civil Procedure 41(a)(1)(ii), each party to bear her or its own costs, expenses and attorney fees. The parties further stipulate that this Court shall retain continuing jurisdiction over any dispute arising out of the settlement of this matter. The parties add that there is no dispute currently and none is anticipated.
Local Civil Rule 7-12, Stipulations, provides:
Every stipulation requesting judicial action must be in writing signed by all affected parties or their counsel. A proposed form of order may be submitted with the stipulation and may consist of an endorsement on the stipulation of the words, "PURSUANT TO STIPULATION, IT IS SO ORDERED," with spaces designated for the date and the signature of the Judge.Pursuant to their settlement and the terms of Local Rule 7-12, the parties respectfully request that the Court enter the Order that follows. So Stipulated:
CONSTANTIN V. ROBOOSTOFF 69328
ROBOOSTOFF & KALKIN
A PROFESSIONAL LAW
CORPORATION
Attorneys for Plaintiff
LORELEI CRESCINI
A PROFESSIONAL CORPORATION
Attorney for Defendant
STANDARD INSURANCE COMPANY
SIGNATURE ATTESTATION
Pursuant to General Order No. 45 § XB, I, Warren H. Nelson, Jr., the e filer of this document, attest that concurrence in the filing of this document has been obtained from the other signatory shown above, Constantin V. Roboostoff, Esq, who is a registered "e filer" with this Court.
WARREN H. NELSON, JR. # 104744 PURSUANT TO STIPULATION, IT IS SO ORDERED. The Clerk shall close this file.
EDWARD J. DAVILA, JUDGE
UNITED STATES DISTRICT COURT