Free Motion to Dismiss - District Court of Colorado - Colorado

Case 1:04-cv-01140-RPM

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Filed 07/12/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-1140-RPM-PAC STEPHANIE J. MARTIN, Plaintiff, vs. HARTFORD LIFE AND ACCIDENT INSURANCE COMPANY, INC., Defendant. ________________________________________________________________________ STIPULATED MOTION FOR ORDER OF DISMISSAL WITH PREJUDICE ________________________________________________________________________ Plaintiff Stephanie J. Martin and Defendant Hartford Life and Accident Insurance Company, Inc., by their respective counsel, hereby stipulate and agree and jointly move the Court to enter an Order of Dismissal with Prejudice as follows: 1. That the complaint and action, including all claims which are or could

have been brought by plaintiff, are dismissed with prejudice pursuant to F.R.C.P. 41(a)(1). 2. That the terms of the Agreement pursuant to which this Stipulation is

being filed are to be kept strictly confidential by plaintiff Martin and that any disclosure of such terms except to her tax advisor or as may be required by law may constitute contempt of Court for which the Court may enter such sanctions as are appropriate. As a further exception to this confidentiality provision, Martin may disclose the fact the case was settled and any aspect of the tax treatment and tax structure of this settlement, but not the amount, to any third party.

Case 1:04-cv-01140-RPM

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3.

That each party will bear her or its own costs and attorneys' fees in

connection with this action. Date: July 12, 2005. Respectfully submitted, s/Gregory A. Eurich Gregory A. Eurich HOLLAND & HART LLP 555 ­ 17th Street, Suite 3200 P. O. Box 8749 Denver, CO 80202 (303) 295-8166 Fax: No. (303) 975-5464 [email protected] ATTORNEYS FOR DEFENDANT HARTFORD LIFE AND ACCIDENT INSURANCE COMPANY, INC.

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s/John Kezer JONES & KELLER, P.C. World Trade Center 1625 Broadway, Suite 1600 Denver, CO 80202 (303) 573-1600 Fax No.: (303) 893-6506 [email protected] ATTORNEYS FOR PLAINTIFF STEPHANIE J. MARTIN
3403652_1.DOC

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Case 1:04-cv-01140-RPM

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