Parks v. Kindred Healthcare, Inc. et al

Northern District of California, cand-4:2015-cv-01788

STIPULATION TO DISMISS THE ENTIRE ACTION WITH PREJUDICE [FED. R. CIV. PRO. 41(A)] AND ORDER. Signed by Judge Saundra Brown Armstrong on 2/23/16.

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1 LAW OFFICES OF RANDAL M. BARNUM Randal M. Barnum, Bar No. 111287 2 rmblaw@pacbell.net Carrie E. Croxall, Bar No. 190430 3 ccroxall@rmblaw.com Lindsay R. Batcha, Bar No. 264192 4 lbatcha@rmblaw.com 279 East H Street 5 Benicia, California 94510 Telephone: (707) 745-3747 6 Facsimile: (707) 745-4580 7 Attorneys for Plaintiff Karen A. Parks 8 9 SHAW VALENZA LLP D. Gregory Valenza, Bar No. 161250 10 gvalenza@shawvalenza.com 980 Ninth Street, Suite 2300 11 Sacramento, California 95814 Telephone: (916) 326-5150 12 Facsimile: (916) 497-0708 13 Attorneys for Defendants Kindred Healthcare, Inc., erroneously sued as 14 Kindred Healthcare Incorporated, and Professional HealthCare at Home, LLC 15 16 UNITED STATES DISTRICT COURT 17 NORTHERN DISTRICT OF CALIFORNIA 18 19 KAREN A. PARKS, an individual, Case No. 4:15-cv-01788-SBA 20 Plaintiff, STIPULATION TO DISMISS THE 21 ENTIRE ACTION WITH PREJUDICE v. [FED. R. CIV. PRO. 41(A)]; [PROPOSED] 22 ORDER KINDRED HEALTHCARE 23 INCORPORATED, PROFESSIONAL HEALTHCARE at HOME, LLC, and Does 24 1-100, inclusive, 25 Defendants. 26 27 28 S HAW V ALENZA LLP ATTORNEYS AT LAW SACRAMENTO STIPULATION TO DISMISS ENTIRE ACTION; [PROPOSED] ORDER 1 IT IS HEREBY STIPULATED by and between the parties to this action through their 2 designated counsel that the above-captioned action be and hereby is dismissed with prejudice 3 pursuant to Fed. R. Civ. Pro. 41(a), each side to bear his or its own costs and attorney's fees. 4 5 SO STIPULATED. 6 7 Dated: February 23, 2016 Respectfully submitted, 8 LAW OFFICES OF RANDAL M. BARNUM 9 10 By: /s/Randal M. Barnum Randal M. Barnum 11 Carrie E. Croxall Lindsay R. Batcha 12 Attorneys for Plaintiff Karen A. Parks 13 14 15 Dated: February 23, 2016 Respectfully submitted, 16 SHAW VALENZA LLP 17 18 By: /s/D. Gregory Valenza D. Gregory Valenza 19 Attorneys for Defendants Kindred Healthcare, Inc., and Professional 20 HealthCare at Home, LLC 21 22 23 24 25 26 27 28 S HAW V ALENZA LLP -2- ATTORNEYS AT LAW SACRAMENTO STIPULATION TO DISMISS ENTIRE ACTION; [PROPOSED] ORDER 1 Filer's Attestation 2 Pursuant to Civil Local Rules, rule 5-1(i)(3), I attest under penalty of perjury that 3 concurrence in the filing of the document has been obtained from its signatory. 4 Dated: February 23, 2016 By: /s/D. Gregory Valenza 5 6 7 Certificate of Service 8 I hereby certify that this document(s) filed through the ECF system will be sent 9 electronically to the registered participants as identified on the Notice of Electronic Filing 10 (NEF) and paper copies will be sent to those indicated as non-registered participants on 11 February 23, 2016. 12 Dated: February 23, 2016 By: /s/D. Gregory Valenza 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 S HAW V ALENZA LLP -3- ATTORNEYS AT LAW SACRAMENTO STIPULATION TO DISMISS ENTIRE ACTION; [PROPOSED] ORDER 1 [PROPOSED] ORDER 2 PURSUANT TO STIPULATION, 3 IT IS HEREBY ORDERED that the above entitled action and Plaintiff Karen A. Parks' 4 First Amended Complaint in this matter are dismissed in its entirety with prejudice pursuant to 5 Fed. R. Civ. Pro. 41(a). 6 IT IS FURTHER ORDERED that each party shall bear her or its own costs and attorney's 7 fees. 8 9 DATED: February 23, 2016 __________________________________ 10 United States District Judge Saundra Brown Armstrong 11 12 438021.2.00133.117 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 S HAW V ALENZA LLP -4- ATTORNEYS AT LAW SACRAMENTO STIPULATION TO DISMISS ENTIRE ACTION; [PROPOSED] ORDER