HomeMy WebLinkAbout2017CV493 - Howard V. City Of Fort Collins, Et Al - 026 - Stipulated Motion For Dismissal Of Defendant City Of Fort CollinsIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:17-cv-00493-RPM
EUGENE HOWARD,
Plaintiff,
v.
CITY OF FORT COLLINS,
Defendant.
STIPULATED MOTION FOR DISMISSAL OF
DEFENDANT CITY OF FORT COLLINS
Plaintiff, Eugene Howard, by and through his attorney, MARK S. BOVE of the law firm
MARK S. BOVE, P.C. and Defendants, City of Fort Collins and Kathleen Walker, by and through
its and her attorneys, CATHY HAVENER GREER, and KATHERINE M.L. PRATT of
WELLS, ANDERSON & RACE, LLC, and JENNY LOPEZ FILKINS, SENIOR
ASSISTANT CITY ATTORNEY, CITY OF FORT COLLINS, hereby submit this Stipulated
Motion for Dismissal of Defendant, City of Fort Collins with prejudice pursuant to Fed. R. Civ. P.
41, as follows:
1. Any and all claims asserted against Defendant, City of Fort Collins, as set forth in
Plaintiff’s Complaint and Jury Demand, and all other pleadings shall be dismissed with prejudice;
2. Defendant City of Fort Collins should be dismissed from this action with prejudice
with each party to pay its own attorneys fees and costs.
Case 1:17-cv-00493-RPM Document 26 Filed 11/27/17 USDC Colorado Page 1 of 3
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WHEREFORE, the parties respectfully request that the Court enter an Order dismissing
Defendant City of Fort Collins with prejudice.
Respectfully submitted this 27th day of November, 2017.
MARK S. BOVE, P.C.
S/ Mark S. Bove
Mark S. Bove
730 17th Street, Suite 365
Denver, CO 80202
T: 303-393-6666
Email: msbove@aol.com
ATTORNEY FOR PLAINTIFF
WELLS, ANDERSON & RACE, LLC
S/ Cathy Havener Greer
Cathy Havener Greer
Katherine M.L. Pratt
1700 Broadway, Suite 1020
Denver, CO 80290
T: 303-830-1212
Email: cgreer@warllc.com
Email: kpratt@warllc.com
S/ Jenny L. Lopez Filkins
Jenny L. Lopez Filkins
City Attorney's Office-Fort Collins
P.O. Box 580
Fort Collins, CO 80522
T: 970-416-2284
Email: jlopezfilkins@fcgov.com
ATTORNEYS DEFENDANTS
Case 1:17-cv-00493-RPM Document 26 Filed 11/27/17 USDC Colorado Page 2 of 3
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on November 27, 2017, a true and correct copy of the above
and foregoing STIPULATED MOTION FOR DISMISSAL OF DEFENDANT CITY OF
FORT COLLINS was electronically filed with the Clerk of Court using the CM/ECF system,
which will send notification of such filing to the following email addresses:
Mark S. Bove, Esq.
Mark S. Bove, P.C.
730 17th Street, Suite 365
Denver, CO 80202
Email: msbove@aol.com
ATTORNEY FOR PLAINTIFF
S/ Barbara McCall
Barbara McCall
Email: bmccall@warllc.com
Case 1:17-cv-00493-RPM Document 26 Filed 11/27/17 USDC Colorado Page 3 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:17-cv-00493-RPM
EUGENE HOWARD,
Plaintiff,
v.
CITY OF FORT COLLINS,
Defendants.
ORDER OF DISMISSAL OF DEFENDANT CITY OF FORT COLLINS
THIS MATTER COMES before the Court on the Stipulated Motion for Dismissal of
Defendant City of Fort Collins with Prejudice pursuant to Fed. R. Civ. P. 41. After carefully
reviewing the file in this matter, I find that the Stipulated Motion should be granted and Defendant
City of Fort Collins should be dismissed with prejudice from this action. Accordingly, it is
ORDERED that the Stipulated Motion for Dismissal of Defendant, City of Fort Collins is
GRANTED. Defendant, City of Fort Collins is DISMISSED WITH PREJUDICE from this
proceeding, and each party to pay its own attorney fees and costs.
SO ORDERED this ______ day by _________, 2017.
BY THE COURT:
______________________________
United States District Court Judge
Case 1:17-cv-00493-RPM Document 26-1 Filed 11/27/17 USDC Colorado Page 1 of 1