HomeMy WebLinkAbout2023-cv-1344 - Sever V. V. City Of Fort Collins, Et Al. - 043 - Stip Dismiss Heaton 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 23-cv-1343-GPG-KLM
CARL SEVER,
Plaintiff,
v.
CITY OF FORT COLLINS,
JASON HAFERMAN,
SERGEANT ALLEN HEATON
JASON BOGOSIAN, and
Defendants.
STIPULATED NOTICE OF DISMISSAL OF DEFENDANT
ALLEN HEATON IN HIS INDIVIDUAL CAPACITY
Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii), the parties, through
undersigned counsel, hereby submit this Stipulated Notice of Dismissal of Defendant
Allen Heaton in his individual capacity, and in support of the same state as follows:
1. Plaintiff notifies the Court of his dismissal of named Defendant Allen Heaton
(individual capacity) from this action.
2. The parties agree that each side shall bear their own attorney’s fees and costs
they’ve incurred up to this point related to their prosecution/defense of any of the
Heaton individual capacity claim(s).
Respectfully submitted this 6th day of December, 2023.
THE LIFE & LIBERTY LAW OFFICE
/s/ Sarah Schielke
Sarah Schielke
Case No. 1:23-cv-01344-NYW-NRN Document 43 filed 12/06/23 USDC Colorado pg 1 of 2
2
The Life & Liberty Law Office LLC
1209 Cleveland Avenue
Loveland, CO 80537
P: (970) 493-1980
F: (970) 797-4008
E: sarah@lifeandlibertylaw.com
Counsel for Plaintiff
HALL & EVANS, LLC
/s/ Mark S. Ratner
Mark S. Ratner, Esq.
1001 17th Street, Suite 300
Denver, CO 80202
Counsel for Defendant Allen Heaton
CERTIFICATE OF SERVICE
This is to certify that on December 6, 2022 a true and accurate copy of the foregoing
Notice has been sent to the following parties by PACER/ECF:
Mark S. Ratner
Email: ratnerm@hallevans.com
Attorneys for Defendants City of Fort Collins,
Sgt Allen Heaton and Jason Bogosian
Jonathan Abramson, Esq.
Yulia Nikolaevskaya, Esq.
Email: jonathan@kandf.com
julie@kandf.com
Attorneys for Defendant Jason Haferman
/s/ Sarah Schielke
Case No. 1:23-cv-01344-NYW-NRN Document 43 filed 12/06/23 USDC Colorado pg 2 of 2