Free Stipulation of Dismissal - District Court of Delaware - Delaware

Case 1:07-cv-00435-SLR

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ROBERT QUILL, Plaintiff, v. CATHOLIC DIOCESE OF WILMINGTON, INC., a Delaware corporation; ST. ELIZABETH'S CATHOLIC CHURCH, a Delaware corporation; Rev. FRANCIS G. DELUCA, individually and in his official capacity, Defendants. : : : : : : : : : : : : : :

C.A.No. 07-435-SLR

STIPULATED ORDER OF DISMISSAL OF REV. FRANCIS G. DELUCA It is hereby STIPULATED and AGREED by and between plaintiff Robert Quill and defendant Rev. Francis G. DeLuca, subject to the approval of the Court, that: 1. Rev. DeLuca's deposition is sealed. 2. Plaintiff's deposition shall not take place. 3. Plaintiff's medical records and other documents produced by plaintiff in discovery shall be immediately destroyed by all defendants. 4. The deposition of Rev. DeLuca can be shown to or discussed with anyone associated with the contemplated or pending litigation relating to Rev. DeLuca upon execution of an affidavit of compliance with the Court's Order and submission to the Court's jurisdiction to address breach of the Court's Order. 5. "Associated with" means: (a) counsel and their staff; (b) any plaintiff; (c) any defendant; (d) immediate family members of any plaintiff; (e) consultative or forensic experts; and (f) healthcare providers. 6. "Associated with" does not mean the media or similar organizations. 1

Case 1:07-cv-00435-SLR

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7. To the extent the deposition must be filed with another court as part of future litigation, mediation, arbitration or other alternative dispute resolution relating to Rev. DeLuca, it shall be filed under seal. 8. In such a court case in any other Delaware court, the sealed judicial record can be unsealed in whole or in part by that court without having to come back to the U.S. District Court for the District of Delaware for permission. 9. The Court retains jurisdiction to entertain any other anticipated applications regarding use of the deposition. 10. All claims of plaintiff Robert Quill against defendant DeLuca are hereby dismissed with prejudice with each side to bear its own costs, expenses and attorneys fees.

THE NEUBERGER FIRM, P.A. /s/ Stephen J. Neuberger THOMAS S. NEUBERGER, ESQ. (#243) STEPHEN J. NEUBERGER, ESQ. (#4440) Two East Seventh Street, Suite 302 Wilmington, DE 19801 (302) 655-0582 [email protected] [email protected] ROBERT JACOBS, ESQ. (#244) THOMAS C. CRUMPLAR, ESQ. (#942) JACOBS & CRUMPLAR, P.A. Two East Seventh Street, Suite 400 Wilmington, DE 19801 (302) 656-5445 [email protected] [email protected] Attorneys for Plaintiff Robert Quill Dated: March 1, 2008

CASARINO CHRISTMAN & SHALK, P.A. /s/ Stephen P. Casarino STEPHEN P. CASARINO, ESQ. (#174) 800 North King Street, Suite 200 P.O. Box 1276 Wilmington, DE 19899 [email protected] Attorney for Defendant Francis G. DeLuca Dated: March 1, 2008

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Case 1:07-cv-00435-SLR IT IS SO ORDERED THIS

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THE HONORABLE SUE L. ROBINSON

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